DCT
1:19-cv-02050
Guada Tech LLC v. DuPont De Nemours Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guada Technologies LLC (Texas)
- Defendant: DuPont de Nemours, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
- Case Identification: 1:19-cv-02050, D. Del., 10/29/2019
- 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 corporate website infringes a patent related to methods for navigating hierarchical data structures using keyword-based searches.
- Technical Context: The technology concerns information retrieval systems, such as complex websites or automated menus, where users navigate through layers of options to find information or complete a transaction.
- Key Procedural History: An Inter Partes Review (IPR) certificate, issued on March 3, 2023, indicates that all claims (1-7) of the patent-in-suit were cancelled as a result of IPR proceedings initiated in 2021. This post-dates the filing of the complaint and is a dispositive event for the patent's enforceability. The complaint also notes the patent was cited as prior art during the prosecution of unrelated patents.
Case Timeline
| Date | Event |
|---|---|
| 2002-11-19 | Priority Date for U.S. Patent No. 7,231,379 |
| 2007-06-12 | U.S. Patent No. 7,231,379 Issued |
| 2019-10-29 | Complaint Filed |
| 2021-05-03 | IPR Proceeding (IPR2021-00875) Filed against ’379 Patent |
| 2021-11-22 | IPR Proceeding (IPR2022-00217) Filed against '379 Patent |
| 2023-03-03 | IPR Certificate Issued Cancelling All Claims (1-7) |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,231,379 - Navigation in a Hierarchical Structured Transaction Processing System
The Invention Explained
- Problem Addressed: The patent describes the problem of navigating large, hierarchical networks of choices, such as automated telephone menus or complex websites. Conventional systems force users to traverse the network sequentially, which can be inefficient and frustrating if a user makes a wrong turn and must backtrack or start over. (’379 Patent, col. 2:9-18; Compl. ¶13).
- The Patented Solution: The invention proposes a method to make this navigation more efficient by allowing a user to "jump" to a desired node without traversing all the intermediate nodes. This is achieved by associating "keywords" with the nodes in the hierarchy. When a user provides an input containing a keyword, the system can identify the corresponding non-adjacent node and navigate directly to it, bypassing the rigid, step-by-step hierarchical structure. (’379 Patent, col. 3:35-43; Compl. ¶14).
- Technical Importance: This method provides a more natural and efficient user experience for interacting with large, structured information systems, a key challenge in the design of websites and automated services. (’379 Patent, col. 2:25-30).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1. (Compl. ¶16).
- The essential elements of 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 that keyword.
- "Jumping" to that identified node.
III. The Accused Instrumentality
Product Identification
The website "https://www.dupont.com/" and its associated subsites, web pages, and functionality (the "Accused Instrumentality"). (Compl. ¶16).
Functionality and Market Context
The complaint alleges the Accused Instrumentality operates as a hierarchical system where product categories represent nodes. (Compl. ¶16). It is alleged that the website’s search box allows a user on a "first node" (e.g., the homepage) to input a query. The system then allegedly identifies a specific product page (a non-adjacent node) related to the query's keywords and allows the user to navigate directly to it, bypassing intermediate category pages. (Compl. ¶16). For instance, a user can allegedly search for "Dow corning emulsifiers" and be taken to that product's node without first traversing a generic "Emulsifiers" category node. (Compl. ¶16).
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 DuPont website homepage (a "first node") provides a search box that accepts user input. This input, such as a product name, contains words that are identifiable with keywords used by the system to locate products. (Compl. ¶16). The complaint provides a diagram of a hierarchical network of nodes to illustrate this structure (Compl. p. 4, Fig. 1). | ¶16 | col. 21:50-57 |
| 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 website's search functionality identifies a product page (a node) associated with the user's keyword input. This product page is allegedly not directly connected to the homepage, as it exists within a deeper level of the site's product category hierarchy. (Compl. ¶16). | ¶16 | col. 21:58-62 |
| jumping to the at least one node. | The website allegedly "allows jumping" to the identified product page/node, enabling the user to bypass the standard navigation path through the site's hierarchy. (Compl. ¶16). | ¶16 | col. 21:63-64 |
Identified Points of Contention
- Scope Questions: A central dispute may concern whether the accused website constitutes a "hierarchical arrangement" as contemplated by the patent. The defense could argue that a modern website's search function relies on a flat database index, and the hierarchical appearance is merely a user interface overlay, not a functional "arrangement" that is "traversed" or "jumped" within.
- Technical Questions: The meaning of "not directly connected" will likely be contested. It raises the question of what evidence demonstrates that a search result link on a homepage is not, in fact, a "direct connection" to the resulting page in the context of web architecture.
V. Key Claim Terms for Construction
"hierarchical arrangement"
- Context and Importance: This term is foundational to the claim, as the entire method operates upon such a structure. The infringement analysis depends on whether the accused website's architecture meets this definition.
- Intrinsic Evidence for a Broader Interpretation: The specification provides varied examples, including telephone voice response systems and interactive television program listings, suggesting the term is not limited to a specific software or data structure but can apply to any system where options are presented in a layered, categorical manner. (’379 Patent, col. 2:40-49).
- Intrinsic Evidence for a Narrower Interpretation: The patent consistently uses graph theory terminology like "tree," "vertices," and "edges," and includes figures depicting formal tree structures. (’379 Patent, Fig. 1; col. 3:9-10). This may support a narrower construction requiring a system that functionally operates as a rigid, pre-defined graph, not merely one with a hierarchical-looking user interface.
"jumping"
- Context and Importance: This term defines the core inventive concept of bypassing the standard hierarchy. Its construction is critical for distinguishing the claimed method from conventional navigation or standard search functions.
- Intrinsic Evidence for a Broader Interpretation: The patent describes "jumping" as a way to "skip from one vertex to another" that may be "many rows down the graph or tree." (’379 Patent, col. 3:30-33). This could be interpreted broadly to cover any action that takes a user to a deep link from a high-level page, such as clicking a search result.
- Intrinsic Evidence for a Narrower Interpretation: The specification explicitly states the invention "eliminates the necessity for making many choices" that would otherwise be required. (’379 Patent, col. 3:33-34). This suggests "jumping" requires more than just following a link; it may require showing that the system actively bypasses specific, defined nodes in a path that a user would otherwise have been forced to traverse.
VI. Other Allegations
The complaint does not contain allegations of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
Structural Definition: A key technical question, now likely moot, is one of structural definition: does the accused website’s search functionality operate within a "hierarchical arrangement" as described in the patent, or is its underlying architecture (e.g., a searchable database with a categorical UI) fundamentally different from the formal "tree" structure the patent appears to describe?
Procedural Finality: The most critical issue for this case is one of procedural finality. Given the March 2023 IPR certificate confirming the cancellation of all claims of the '379 patent, the central question is what impact this invalidation has on the viability of the lawsuit, which was filed when the patent was still presumed valid.