DCT
1:19-cv-00186
Guada Tech LLC v. BSN Sports LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guada Technologies LLC (Texas)
- Defendant: Sport Supply Group, Inc. (Delaware)
- Plaintiff’s Counsel: Devlin Law Firm LLC; Direction IP Law
- Case Identification: 1:19-cv-00186, D. Del., 01/30/2019
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for navigating hierarchical data structures using keyword-based searches.
- Technical Context: The technology concerns systems, such as websites or interactive voice response menus, that allow a user to navigate directly to specific information using a keyword, thereby bypassing intermediate categorical steps.
- 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, an Inter Partes Review (IPR) proceeding at the U.S. Patent and Trademark Office (IPR2021-00875) resulted in a certificate, issued March 3, 2023, cancelling all claims (1-7) of the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2002-11-19 | U.S. Patent No. 7,231,379 Priority Date (Application Filing) |
| 2007-06-12 | U.S. Patent No. 7,231,379 Issued |
| 2019-01-30 | Complaint Filed |
| 2023-03-03 | U.S. Patent No. 7,231,379, Claims 1-7 Cancelled via IPR |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,231,379 - Navigation in a Hierarchical Structured Transaction Processing System, Issued June 12, 2007 (’379 Patent)
The Invention Explained
- Problem Addressed: The patent describes conventional navigation through hierarchical networks, such as automated telephone menus, as potentially inefficient and frustrating for users (Compl. ¶13; ’379 Patent, col. 2:9-18). As these networks grow larger, navigating through an excessive number of choices or recovering from a wrong turn becomes increasingly difficult (Compl. ¶13; ’379 Patent, col. 2:12-18).
- The Patented Solution: The invention proposes a method to make navigation more efficient by allowing the system to "jump" from a starting point directly to a relevant destination node, bypassing intermediate nodes in the hierarchy (Compl. ¶14; ’379 Patent, col. 3:30-37). This is accomplished by receiving a user's input containing a keyword, using that keyword to identify a non-adjacent destination node associated with it, and navigating directly to that node (Compl. ¶14; ’379 Patent, col. 3:37-43). The patent describes using an "inverted index" to create the association between keywords and nodes (’379 Patent, col. 5:61-64).
- Technical Importance: This method provides a more direct and user-friendly way to access information in complex data systems, moving beyond the rigid, step-by-step traversal required by traditional hierarchical menus (’379 Patent, col. 2:20-30).
Key Claims at a Glance
- The complaint’s specific infringement allegations focus on Claim 1 (’379 Patent, col. 21:47-22:2; Compl. ¶16).
- The essential elements of independent Claim 1 are:
- A method performed in a system with multiple navigable nodes in a hierarchical arrangement.
- At a first node, receiving a user input that contains at least one word identifiable with a keyword.
- Identifying at least one other node that is not directly connected to the first node but is associated with the keyword.
- Jumping to that identified node.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the website located at https://www.bsnsports.com/, including its associated subsites, web pages, and functionality (Compl. ¶16).
Functionality and Market Context
The complaint alleges that the website utilizes a hierarchical arrangement of product categories, which it equates to the claimed "nodes" (Compl. ¶16). For example, a user might navigate from a home page to a general "Apparel" category and then to a specific product. The complaint alleges that the website's search box allows a user to input a keyword, which the system uses to identify a specific product page and "jump" the user directly to it, bypassing intermediate category nodes (Compl. ¶16). A diagram, reproducing Figure 1 of the patent, is included in the complaint to illustrate a generic hierarchical network of numbered nodes connected by edges (Compl. p. 4).
IV. Analysis of Infringement Allegations
’379 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method performed in a system having multiple navigable nodes interconnected in a hierarchical arrangement... | The Accused Instrumentality has different product categories ("nodes") for selection, such as "Apparel" and "Footwear," which are interconnected in a hierarchical arrangement from the home page node. | ¶16 | col. 21:47-49 |
| 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 system uses a search box on the home page node ("first node") for accepting an input from a user. The input contains one or more words identifiable with a keyword used by the defendant to identify products. | ¶16 | 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, and | The system identifies a particular product ("node") that relates to the keyword entered by the user. This product node is not directly connected to the home page node. | ¶16 | col. 22:55-60 |
| jumping to the at least one node. | The system "allows jumping to those items/nodes without traversing preceding generic category nodes (e.g., 'Apparel', 'Footwear', etc.) in the hierarchy." | ¶16 | col. 22:1-2 |
Identified Points of Contention
- Scope Questions: A central question may be whether a standard e-commerce website, with its product categories and search functionality, constitutes the "hierarchical arrangement" of "nodes" described in the patent, which provides examples such as interactive voice response (IVR) systems (’379 Patent, col. 4:40-43). The interpretation of what it means for a node to be "not directly connected to the first node" in the context of hyperlinked web pages may also be a point of dispute (Compl. ¶16).
- Technical Questions: The analysis may focus on whether the accused website's search function performs the specific act of "jumping" as claimed, or if it simply executes a standard database query and displays a list of results, which may be technically distinct. The complaint alleges "jumping" occurs by "allowing jumping to those items/nodes without traversing preceding generic category nodes," raising the question of what evidence will support this specific traversal-avoidance mechanism (Compl. ¶16).
V. Key Claim Terms for Construction
The Term: "hierarchical arrangement"
- Context and Importance: The applicability of the patent to the accused website hinges on this term. Practitioners may focus on this term because its construction will determine whether a typical e-commerce site architecture falls within the patent's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the invention's applicability to a "wide range of different networks, which can be mathematically represented by graph structures," including a "file system browser for personal computer operating systems" or a "navigation system for television program listing" (’379 Patent, col. 3:59-col. 4:2).
- Evidence for a Narrower Interpretation: The specification repeatedly uses the term "menu tree" and provides detailed examples centered on structured, choice-based systems like IVR, which may suggest a more constrained structure than a general website (’379 Patent, col. 3:9, col. 13:1-14).
The Term: "jumping"
- Context and Importance: This term defines the core inventive step. The dispute will likely turn on whether the accused website's standard search-to-result navigation constitutes "jumping."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract describes "jumping to the identified node," and the claim language itself does not specify the underlying mechanism beyond moving to the new node (’379 Patent, Abstract).
- Evidence for a Narrower Interpretation: The specification explains that "jumping" is a way to "skip from one vertex to another" and "eliminates the necessity for making many choices" along a predefined path, thereby "avoiding the need to traverse intervening nodes" (’379 Patent, col. 3:30-34, col. 6:17-19). This may imply more than simply linking from a search results page.
VI. Other Allegations
Indirect Infringement
The complaint focuses its factual allegations on direct infringement, stating Defendant infringes by "making, using, and/or performing a method" through the operation of its website (Compl. ¶16). The complaint does not plead specific facts to support claims of induced or contributory infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- Procedural Viability: Given the post-filing cancellation of all claims of the '379 patent by the U.S. Patent and Trademark Office, the primary question is one of case survival: does this lawsuit have any remaining legal basis, or is it moot pending a successful, and unlikely, reversal of the agency's final decision?
- Definitional Scope: A core infringement question, should the claims ever be revived, will be one of technical analogy: can the patent's claims, which are explained using examples like interactive phone menus and television guides, be properly construed to cover the functionally distinct environment of a modern e-commerce website with a keyword search bar?
- Functional Operation: An evidentiary question will be one of mechanism: does the accused website’s search function perform the specific, claimed method of "jumping" to a non-adjacent node within a defined hierarchy, or does it simply execute a conventional database query and present results, an operation that may be technically distinguishable from the patented process?