DCT

1:19-cv-01444

Sentius Intl LLC v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-01444, D. Del., 07/31/2019
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Apple Inc. has a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that the spell-check functionality in Defendant’s iOS, macOS, and iCloud products infringes patents related to systems for linking textual data to external reference materials and for syndicating database content.
  • Technical Context: The technology concerns real-time document analysis, specifically identifying words (e.g., misspelled words) and linking them to external data sources (e.g., dictionaries) for display, a foundational feature in modern software.
  • Key Procedural History: The complaint alleges pre-suit knowledge for both patents-in-suit based on letters with claim charts sent to Apple in July 2015 and June 2018. Subsequent to the complaint's filing, an Inter Partes Review (IPR) was initiated against the '985 Patent, which resulted in the cancellation of all asserted claims, a development that may render the infringement counts related to that patent moot. The '633 Patent is a reissue of U.S. Patent No. 5,822,720.

Case Timeline

Date Event
1994-02-16 Priority Date for U.S. Reissued Patent No. RE43,633
2001-08-16 Priority Date for U.S. Patent No. 7,672,985
2010-03-02 Issue Date for U.S. Patent No. 7,672,985
2012-09-04 Issue Date for U.S. Reissued Patent No. RE43,633
2015-07-20 Plaintiff allegedly sent pre-suit notice to Defendant regarding the '633 Patent
2018-06-27 Plaintiff allegedly sent pre-suit notice to Defendant regarding the '985 Patent
2019-07-31 Complaint Filing Date
2020-10-01 Inter Partes Review (IPR2020-01646) filed against the '985 Patent
2024-04-16 IPR Certificate issued cancelling asserted claims of the '985 Patent

II. Technology and Patent(s)-in-Suit Analysis

U.S. Reissued 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 for users, particularly students of a foreign language like Japanese, in understanding unfamiliar text due to the need for cumbersome dictionary lookups that disrupt the reading process (RE43,633 Patent, col. 1:21-30; col. 2:49-65).
  • The Patented Solution: The invention is a system that indexes a document and links words or phrases to external reference materials. When a user clicks on a word, the system uses the position of the click to calculate a character offset, consults a look-up table to find the corresponding link, and displays the relevant reference material (e.g., a definition or translation) in a pop-up window, allowing the user to get information without leaving the document (RE43,633 Patent, Abstract; col. 6:40-67).
  • Technical Importance: This method created a more integrated and seamless way to access contextual information within digital documents, reducing the friction associated with reading difficult or foreign-language material (RE43,633 Patent, col. 4:4-14).

Key Claims at a Glance

  • The complaint asserts independent claims 17, 62, 101, and 146, with a detailed breakdown provided for claim 17 (Compl. ¶17, 20). Independent claim 17 is written in means-plus-function format under 35 U.S.C. § 112(f).
  • Essential elements of independent claim 17 include:
    • means for determining a beginning position address of textual source material
    • means for cutting the textual source material into a plurality of discrete pieces
    • means for determining starting and ending point addresses of the discrete pieces
    • means for recording the starting and ending point addresses in a look-up table
    • means for linking the discrete pieces to 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 portion
    • means for converting the display address to an offset value
    • means for comparing the offset value with addresses in the look-up table
    • means for selecting a corresponding external reference material
    • means for displaying the selected external reference material
  • The complaint asserts dependent claim 18 and reserves the right to assert others (Compl. ¶33).

U.S. Patent No. 7,672,985 - "Automated Creation and Delivery of Database Content," issued March 2, 2010

The Invention Explained

  • Problem Addressed: The patent identifies a need for a more scalable and cost-effective system to create and manage "richly linked associations between terms and related content," noting that prior methods were often manual and inconsistent ('985 Patent, col. 1:53-62).
  • The Patented Solution: The invention outlines a method and system for automatically building a central database and syndicating its content. The system identifies terms in documents, which can then be annotated by experts. It then creates and syndicates "data objects" (e.g., dictionaries and rule sets) to remote computers, which use these local data objects to perform linking without needing a constant connection to the central server ('985 Patent, Abstract; col. 2:45-58).
  • Technical Importance: The technology provides a distributed architecture that enables applications on client devices to perform sophisticated, context-aware content linking using locally-cached, periodically updated data, improving performance and scalability.

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a method) and 11 (a system) (Compl. ¶45).
  • Essential elements of independent claim 1 include:
    • syndicating one or more data objects associated with a term database to one or more remote computers
    • parsing one or more documents to identify at least one term based on at least one rule
    • identifying content for the at least one term
    • associating the at least one term with the identified content
    • wherein the syndicated data objects provide a representation of the term database on the remote computers and are used to link the content to the term.
  • The complaint also asserts independent claim 11 (Compl. ¶51).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are a broad range of Apple hardware and software, including iOS devices (e.g., iPhone 5-6 Plus, various iPads), Mac devices (e.g., MacBook Pro, iMac), and associated applications such as "Mail," "Messages," "Notes," "TextEdit," and "Safari." The allegations also cover online applications like iCloud Keynote and iCloud Pages (Compl. ¶13-14).

Functionality and Market Context

  • The core accused functionality is the "red squiggly" spell check feature common across Apple's operating systems and applications (Compl. ¶11). The complaint alleges this feature identifies misspelled words, marks them, and upon user selection (e.g., a click or tap), retrieves and displays suggested corrections from a linked spell-check dictionary (Compl. ¶11, 21). The '985 Patent allegations further describe a system architecture where Apple servers maintain a master dictionary database and syndicate updated spell-check dictionaries to user devices for local operation (Compl. ¶16, 46).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

'RE43,633 Patent Infringement Allegations

Claim Element (from Independent Claim 17) Alleged Infringing Functionality Complaint Citation Patent Citation
means for determining a beginning position address of textual source material stored in an electronic database. The accused document editor allegedly assigns a zero position address to the first character of the document text. ¶22 col. 6:40-44
means for cutting the textual source material into a plurality of discrete pieces. A parser in the accused products allegedly parses the document to cut text into individual words and phrases. ¶23 col. 7:5-9
means for determining starting point addresses and ending point addresses of the plurality of discrete pieces... A parser allegedly identifies the beginning and ending character position offsets for misspelled words. ¶24 col. 7:35-40
means for recording in a look-up table the starting and ending point addresses. Software instructions allegedly maintain a data structure storing the beginning and ending character offsets for potentially misspelled words. ¶25 col. 6:55-60
means for linking the plurality of discrete pieces to external reference materials... Software instructions allegedly store a pointer in the data structure linking the misspelled word to suggested spellings in a dictionary. ¶26 col. 7:13-19
means for selecting a discrete portion of an image of the source material. The system allows a user to click on a highlighted misspelled word through a touch interface. ¶27 col. 6:49-54
means for converting the display address of the selected discrete portion to an offset value... Software allegedly converts the coordinates of the user's touch input into a character position offset value. ¶29 col. 6:50-54
means for comparing the offset value with the starting and ending point addresses recorded in the look-up table... Software allegedly compares the character position offset value with entries in the data structure to identify the corresponding entry. ¶30 col. 6:55-60
means for selecting one of the external reference materials corresponding to the identified one of the plurality of discrete pieces. Software instructions allegedly resolve the pointer to identify and retrieve corresponding correct spellings from the spell check dictionary. ¶31 col. 7:13-24
means for displaying on a computer the selected one of the... external reference materials. The software allegedly displays the retrieved correct spellings as suggested corrections to the user. ¶32 col. 7:20-24
  • Identified Points of Contention:
    • Scope Questions: A primary issue will be the scope of the "means for" limitations under 35 U.S.C. § 112(f). The analysis will question whether the structures in Apple’s modern software (e.g., its "parser") are structurally equivalent to the specific "grammar parser" and "link engine" disclosed in the patent's specification, which dates to a 1994 priority filing (RE43,633 Patent, FIG. 1).
    • Technical Questions: What evidence does the complaint provide that Apple's system performs the specific step of "converting the display address" (screen coordinates) to a character "offset value"? The court may need to determine if Apple's technology uses this specific mechanism or an alternative, non-infringing method for identifying the selected text.

'985 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
syndicating one or more data objects associated with a term database to one or more remote computers... Apple allegedly transmits spell check dictionary files from a master database on its servers to user computers for local use. ¶46 col. 2:15-21
parsing one or more documents to identify at least one term based on at least one rule. The accused applications allegedly use a parser to identify character strings and their offset positions based on grammar/parsing rules. ¶47 col. 5:56-61
identifying content for the at least one term. The accused applications allegedly use the spell check dictionary to identify suggested spellings for a given misspelled word. ¶48 col. 2:31-38
associating the at least one term with the identified content. The system allegedly links the misspelled word to suggested spellings in the dictionary and displays them in a pop-up window. ¶49 col. 13:19-22
wherein the one or more data objects... provide a representation of at least a portion of the term database at the... remote computers and are used to link the identified content... The local spell check dictionary allegedly represents the master database and is used to link misspelled words to suggested spellings. ¶50 col. 2:49-58
  • Identified Points of Contention:
    • Scope Questions: The interpretation of "syndicating" will be critical. The court will have to decide if Apple's standard process for updating application data and dictionaries on user devices falls within the patent's description of syndication from a central database for the purpose of enabling a remote linking engine.
    • Technical Questions: Does the accused system's process of identifying a word as misspelled because it is absent from a dictionary constitute identifying a term "based on at least one rule" as contemplated by the patent, or is this a fundamentally different technical operation?

V. Key Claim Terms for Construction

For the 'RE43,633 Patent:

  • The Term: "means for cutting the textual source material into a plurality of discrete pieces" (from claim 17).
  • Context and Importance: As a means-plus-function limitation, the construction of this term is not its plain meaning but is instead limited to the specific structures disclosed in the specification for performing the function, and their equivalents. Practitioners may focus on this term because its scope will determine whether Apple's modern text parser can be found to infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function in general terms, such as dividing text into "the individual components" (RE43,633 Patent, col. 7:7-9), which could support a reading on any form of text tokenization.
    • Evidence for a Narrower Interpretation: The primary structure disclosed for performing this function is a "grammar parser" (23) (RE43,633 Patent, FIG. 1). A defendant could argue this limits the claim to structures that perform linguistic or grammatical analysis, not merely identifying words based on spaces or punctuation.

For the '985 Patent:

  • The Term: "syndicating" (from claim 1).
  • Context and Importance: This term defines the core distribution model of the invention. Its construction will be central to determining if Apple's system architecture infringes. The dispute may hinge on whether "syndicating" requires the specific push-model from a central content-creation database to a remote processing engine, as described in the patent, or if it can cover more general software update mechanisms.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition for "syndicating," which may allow a party to argue for its plain and ordinary meaning, potentially covering any form of distributing data for republication or use.
    • Evidence for a Narrower Interpretation: The specification describes a specific process where a "RichLink Processor automatically downloads... the data structures necessary" from a "central database" and "performs routine synchronization" ('985 Patent, col. 2:49-58). This suggests a specific client-server architecture for content delivery, potentially narrowing the term's scope.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Apple induces infringement by "aiding and encouraging" users to use the accused spell-check functionality. It also alleges Apple is directly responsible for its users' infringement because it "directs and/or controls the user's performance of those actions" through the design of its products (Compl. ¶37-38, 59-60).
  • Willful Infringement: Willfulness is alleged for both patents based on pre-suit notice. The complaint states Apple received letters with claim charts regarding the '633 Patent in July 2015 and the '985 Patent in June 2018, allegedly establishing knowledge of infringement (Compl. ¶35, 57). The complaint further alleges willfulness based on Apple's failure to take a license after being apprised of the infringement (Compl. ¶61).

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

  • A threshold issue is the viability of the '985 Patent claims: given the subsequent cancellation of all asserted claims of the '985 Patent in an Inter Partes Review, the court will first need to address whether the infringement allegations in Count Two are moot.
  • For the remaining '633 Patent, a core issue will be one of structural equivalence under § 112(f): can the software architecture of Apple’s modern spell-check system be considered equivalent to the specific "grammar parser" and "link engine" structures disclosed in the patent’s mid-1990s specification, or has technology evolved to a point where the accused systems are non-equivalent?
  • A key evidentiary question will be one of operational mapping: does the plaintiff's theory, based largely on "information and belief," accurately map the functionality of the accused products onto the specific, sequential steps of the patent's claims, particularly the conversion of a screen "display address" to a text "offset value" for a lookup-table comparison?