Guada Tech LLC v. Deere & Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Guada Technologies LLC (Texas)
  • Defendant: Deere & Company (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:19-cv-01764, D. Del., 09/19/2019
• Venue Allegations: Venue is alleged to be proper in Delaware because Defendant is a Delaware corporation.
• Core Dispute: Plaintiff alleges that Defendant’s corporate website, which features a keyword search function, infringes a patent related to methods for navigating hierarchical data structures.
• Technical Context: The technology concerns user interface navigation for information systems, aiming to improve efficiency by allowing users to bypass rigid, step-by-step menu structures.
• Key Procedural History: The complaint notes that the asserted patent 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 U.S. Patent and Trademark Office instituted Inter Partes Review proceedings (IPR2021-00875, IPR2022-00217) against the patent-in-suit. On March 3, 2023, an IPR Certificate was issued cancelling all claims (1-7) of the patent, rendering them unenforceable and likely rendering this litigation moot.

Case Timeline

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 inefficiency and user frustration associated with navigating conventional hierarchical information systems, such as automated telephone menus or early websites (Compl. ¶13; ’379 Patent, col. 2:9-18). In these systems, a user who makes a wrong selection must often backtrack through previous steps or start the entire process over.
• The Patented Solution: The invention proposes a method to bypass this rigid, step-by-step navigation. It achieves this by associating keywords with the various "nodes" (or options) within the hierarchy. When a user provides an input containing a recognized keyword, the system can "jump" directly to a relevant node, even if it is not directly connected to the user's current position in the hierarchy, thereby avoiding traversal through intervening nodes (Compl. ¶14; ’379 Patent, col. 3:35-43). The complaint includes a diagram from the patent, showing a generic hierarchical network of numbered nodes connected by edges, to illustrate the type of structure at issue (Compl. p. 3).
• Technical Importance: This approach seeks to make user interaction with complex data systems more efficient and intuitive by allowing for non-linear navigation that more closely mirrors a user's intent (Compl. ¶11; ’379 Patent, col. 2:22-30).

Key Claims at a Glance

• The complaint asserts infringement of at least claim 1 of the '379 patent (Compl. ¶16).
• The essential elements of independent claim 1 are:
  • A method performed in a system with "multiple navigable nodes interconnected 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 "node," other than the first node, that is "not directly connected to the first node" but is associated with the keyword.
  • "Jumping to the at least one node."
• The complaint's prayer for relief requests judgment on "one or more claims," implicitly reserving the right to assert other claims (Compl. p. 6).

III. The Accused Instrumentality

Product Identification

• The website at "https://www.deere.com/" and its associated subsites, web pages, and functionality (the "Accused Instrumentality") (Compl. ¶16).

Functionality and Market Context

• The complaint alleges the Accused Instrumentality utilizes a hierarchical arrangement of "nodes" in the form of product categories (e.g., "Agriculture," "Lawn & Garden," "Construction") and sub-categories (e.g., "Zero-Turn Mowers," "Lawn Tractors") (Compl. ¶16).
• It further alleges that the website's search box functions as a means of "receiving an input from a user" that contains keywords, which are then used to identify particular products (Compl. ¶16).
• The complaint does not provide sufficient detail for analysis of the product's commercial importance or market positioning beyond its existence as the Defendant's primary corporate and e-commerce website.

IV. Analysis of Infringement Allegations

• '379 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question is whether the architecture of a modern website, with its web of hyperlinks and dynamic search results, constitutes the "hierarchical arrangement" of "navigable nodes" described in the patent (’379 Patent, col. 3:9-11). The defense could argue the patent's focus on rigid "menu tree" structures is distinct from the more fluid nature of the accused website.
  • Technical Questions: The analysis may turn on whether the website's search functionality performs the claimed "jumping" to a pre-defined "node." The complaint alleges a "jump" occurs when the system navigates to a product page (Compl. ¶16). A potential dispute is whether displaying a dynamically generated search results page or linking to a product page is technically equivalent to the patent's concept of "jumping" to a specific, non-adjacent node within a fixed hierarchy.

V. Key Claim Terms for Construction

• The Term: "navigable nodes interconnected in a hierarchical arrangement"

• Context and Importance: This term defines the environment in which the invention operates. The infringement case depends on whether the structure of the Deere website can be mapped onto this limitation. Practitioners may focus on this term because its interpretation will determine if the patent's teachings, rooted in early 2000s technology like IVR systems, apply to modern web architecture.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification uses general graph theory language, describing the invention's environment as a "graph structure" with "vertices" and "edges," which could arguably encompass a website's link structure (’379 Patent, col. 2:32-37).
  • Evidence for a Narrower Interpretation: The patent repeatedly uses the term "menu tree" and provides detailed examples based on automated telephone voice response systems, suggesting a more rigid, discrete, and pre-defined structure than a typical website (’379 Patent, col. 2:40-60; col. 3:9-11).

• The Term: "jumping to the at least one node"

• Context and Importance: This term describes the core inventive act that distinguishes the claimed method from conventional, linear navigation. The infringement finding hinges on whether the accused website's search-and-navigate functionality constitutes "jumping."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent abstract describes "jumping to the identified node," and the complaint alleges this occurs when the website navigates a user to a product page without traversing the categorical hierarchy (Compl. ¶16; ’379 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The specification describes the action as allowing a system to "jump laterally from one branch to another" or to "bypass intervening nodes" (’379 Patent, col. 3:35-37; col. 4:35-43). A party could argue that generating a search results page is a separate database query function, not a "jump" between specific, pre-existing nodes within the hierarchy itself.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific factual allegations to support claims for either induced or contributory infringement. The allegations focus on Defendant's direct performance of the claimed method (Compl. ¶16).
• Willful Infringement: The complaint does not explicitly allege willful infringement or plead specific facts—such as pre-suit knowledge of the patent and infringement—that would typically be used to support such a claim.

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

The disposition of this case is overwhelmingly dictated by a post-filing procedural event. The key questions are:

1. A threshold question of mootness: Given that the U.S. Patent and Trademark Office cancelled all claims of the '379 patent in 2023, does any legally cognizable case or controversy remain for the court to adjudicate?
2. A core substantive question of definitional scope: Had the patent survived, a central issue would have been whether the term "hierarchical arrangement", which the patent illustrates with rigid "menu tree" examples from the early 2000s, could be construed to read on the dynamic, hyperlink-based structure of a modern commercial website.
3. A key evidentiary question of technical operation: The case would also have presented a factual dispute over whether the accused website's search function, which generates a list of results, performs the specific claimed step of "jumping to... at least one node", or if it operates via a technically distinct mechanism not covered by the claims.