DCT
1:19-cv-00187
Guada Tech LLC v. Uncommongoods LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guada Technologies LLC (Texas)
- Defendant: Uncommongoods, L.L.C. (Delaware)
- Plaintiff’s Counsel: Devlin Law Firm LLC
- Case Identification: 1:19-cv-00187, D. Del., 01/30/2019
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware limited liability company.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for navigating hierarchical data structures by allowing users to "jump" to non-adjacent information nodes.
- Technical Context: The technology addresses inefficiencies in navigating hierarchical information systems, such as website menus or automated phone systems, by enabling direct access to content via keyword inputs, bypassing sequential step-by-step navigation.
- 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. Significantly, the provided patent document includes an Inter Partes Review (IPR) Certificate, issued on March 3, 2023, stating that all claims of the patent (Claims 1-7) have been cancelled as a result of IPR proceedings. This post-complaint event raises a dispositive question about the ongoing validity of the asserted patent.
Case Timeline
| Date | Event |
|---|---|
| 2002-11-19 | Priority Date for U.S. Patent No. 7,231,379 |
| 2007-06-12 | Issue Date for U.S. Patent No. 7,231,379 |
| 2019-01-30 | Complaint Filing Date |
| 2021-05-03 | IPR2021-00875 Filed |
| 2021-11-22 | IPR2022-00217 Filed |
| 2023-03-03 | IPR Certificate Issued; Claims 1-7 Cancelled |
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)
The Invention Explained
- Problem Addressed: The patent addresses the inefficiency and user frustration associated with navigating large, hierarchical information networks, such as automated telephone menus or complex websites. In such systems, users must traverse a rigid, step-by-step path, and an incorrect choice may require them to backtrack or start over completely (’379 Patent, col. 2:9-18; Compl. ¶13).
- The Patented Solution: The invention proposes a method to bypass this rigid structure by allowing a user to "jump" from one point in the hierarchy to a non-adjacent destination node. This is achieved by associating nodes with keywords; when a user provides an input containing a matching keyword, the system can identify and navigate directly to the relevant node, skipping any intermediate steps ('379 Patent, col. 3:35-43, Abstract; Compl. ¶14). The patent uses a diagram of a generic hierarchical tree to illustrate the arrangement of nodes and edges that a user would typically have to traverse (Compl. p. 4, FIG. 1).
- Technical Importance: The method aimed to make user interaction with complex data systems more efficient and natural, and the complaint notes its citation history in patents from major technology corporations, suggesting its relevance to the field (Compl. ¶15).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 ('379 Patent, Claim 1; Compl. ¶16).
- Independent Claim 1 recites:
- A method performed in a system having multiple navigable nodes interconnected in a hierarchical arrangement,
- 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.
- Plaintiff reserves the right to assert other claims of the ’379 patent (Compl. ¶18).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the website located at
https://www.uncommongoods.com/, including its associated sub-sites and functionality (Compl. ¶16).
Functionality and Market Context
- The complaint alleges the website is structured with multiple navigable nodes, including a home page and various product categories ("Gifts," "Fun," etc.) arranged in a hierarchy (Compl. ¶16).
- The key accused functionality is the website's search box. The complaint alleges that when a user enters a keyword into the search box on the home page (the "first node"), the system allows the user to "jump" directly to a particular product page without first traversing the intermediate category nodes (Compl. ¶16).
- The complaint alleges that the Defendant derives revenue from these allegedly infringing acts within Delaware and elsewhere (Compl. ¶5).
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 Uncommongoods website provides a search box on its home page (the "first node") for accepting a user's typed input, which contains words used to identify products. | ¶16 | col. 6:7-15 |
| 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 specific product page (a "node") that is associated with the user's keyword input. This product page is not directly linked from the home page but exists deeper within the site's category hierarchy. | ¶16 | col. 6:7-14 |
| and jumping to the at least one node. | The system allows the user to navigate directly to the identified product page, bypassing the need to click through the preceding generic category nodes in the hierarchy. | ¶16 | col. 6:15-20 |
- Identified Points of Contention:
- Scope Questions: A primary issue may be whether the components of a modern e-commerce website map to the patent's terminology. For example, does a dynamically generated search results page or a final product page constitute a "node" in a "hierarchical arrangement" as contemplated by the patent, which provides examples like interactive voice response (IVR) menus ('379 Patent, col. 4:46-51)?
- Technical Questions: The analysis may turn on the technical distinction between the claimed "jumping" and a standard website search function. A question for the court is whether executing a database query based on a keyword and displaying the results is the same as the patent's described process of navigating between pre-defined nodes in a tree structure.
V. Key Claim Terms for Construction
The Term: "node"
- Context and Importance: The entire infringement theory rests on construing components of the accused website (e.g., home page, category pages, product pages) as "nodes." The viability of the case depends on whether this term is broad enough to cover these web elements.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes a "node" as representing a "specific choice or option in the hierarchy" ('379 Patent, col. 4:26-27) and more generally refers to "vertices" in a graph structure ('379 Patent, col. 2:33-35), language that could support encompassing various distinct web pages.
- Evidence for a Narrower Interpretation: The patent’s examples frequently depict nodes as discrete, pre-defined steps in a menu, such as options in an airline reservation IVR system or a television program guide ('379 Patent, FIG. 4, FIG. 6). This could support a narrower construction limited to menu-like options, potentially excluding final content pages like a product description.
The Term: "jumping"
- Context and Importance: This term describes the central infringing act. The dispute will likely focus on whether a conventional web search qualifies as "jumping." Practitioners may focus on this term because its definition distinguishes the invention from simple linking.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the invention as allowing a user to "skip from one vertex to another" that may be "many rows down the graph or tree" ('379 Patent, col. 3:30-32). This could be argued to cover any non-sequential navigation that bypasses intermediate steps.
- Evidence for a Narrower Interpretation: The specification contrasts the invention with traversing a tree "in the rigid hierarchical manner" ('379 Patent, col. 5:10-12). This suggests "jumping" is a specific navigational act within a defined hierarchy, which a party could argue is technically different from a database query that is untethered to a rigid tree structure.
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A dispositive threshold question will be the viability of the patent itself. The provided documentation includes a 2023 IPR certificate indicating that all claims of the ’379 patent have been cancelled. The court will need to address the effect of this post-complaint cancellation on the entire action.
- Assuming the patent were valid, a core issue would be one of definitional scope: can the term "node," rooted in the patent's context of discrete IVR and menu-tree options, be construed to cover the dynamically generated product pages of a modern e-commerce website?
- A central evidentiary question would be one of functional operation: does the accused website's keyword-based search function perform the claimed method of "jumping" between nodes within a "hierarchical arrangement," or does it represent a fundamentally different technical process (e.g., a database query) that falls outside the patent's scope?