Guada Tech LLC v. United Rentals Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Guada Technologies LLC (Texas)
  • Defendant: United Rentals, Inc. (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm P.A.
• Case Identification: 1:20-cv-00695, D. Del., 05/26/2020
• Venue Allegations: Venue is asserted based on Defendant’s incorporation in the state of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for navigating hierarchical information systems.
• Technical Context: The technology concerns systems, such as websites or interactive voice response menus, that allow users to bypass rigid, step-by-step navigation by using keyword-based "jumps" to non-adjacent destinations.
• 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, the patent was subject to inter partes review (IPR) proceedings (IPR2021-00875, IPR2022-00217). An IPR certificate issued on March 3, 2023, confirmed that all claims of the patent, including the one asserted in this case, have been cancelled. This cancellation presents a fundamental challenge to the viability of the infringement action.

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 conventional navigation through hierarchical networks, such as automated telephone menus or complex websites, as inefficient and frustrating for users. As the number of nodes increases, navigating through sequential choices to reach a goal can be difficult, and a wrong turn may require the user to backtrack or start over completely (’379 Patent, col. 2:9-18; Compl. ¶13).
• The Patented Solution: The invention proposes a method to make navigation more efficient by allowing a user to "jump" from one point in the hierarchy to another, non-adjacent point. This is achieved by associating keywords with the various nodes (or destinations) in the system. When a user provides an input, the system identifies keywords in that input and uses them to find the associated node, bypassing the intermediate hierarchical steps (’379 Patent, Abstract; col. 3:35-43). The complaint includes a generic hierarchical tree diagram from the patent's Figure 1 to illustrate the concept of nodes and edges (Compl. p. 4).
• Technical Importance: This method provides a more flexible and direct navigation experience, moving beyond rigid menu trees toward the type of keyword-based search functionality common in modern web applications and information retrieval systems (’379 Patent, col. 4:1-6).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶16). The prayer for relief seeks judgment on "one or more claims" (Compl. p. 7, ¶a).
• Independent Claim 1 requires:
  • 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 a node, other than the first node, that is not directly connected to the first node but is associated with the keyword.
  • Jumping to the identified node.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant's website, https://www.unitedrentals.com/, and its associated subsites, web pages, and functionality (Compl. ¶16).

Functionality and Market Context

• The complaint alleges the website operates as a hierarchical system where users can navigate through product categories (e.g., Equipment -> Earth Moving Equipment -> Bull Dozers). The complaint asserts that the website’s search box, located on the home page, allows a user to input a term (e.g., "110 HP"), which the system uses as a keyword to identify a specific product page. This functionality is alleged to cause a "jump" directly to the product page, bypassing the need to traverse the intermediate category nodes in the hierarchy (Compl. ¶16). The complaint does not provide detail regarding the product's commercial importance.

IV. Analysis of Infringement Allegations

’379 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be the definition of "not directly connected to the first node." Defendant could argue that its search function leads to a search results page, which is itself a node directly linked from the homepage, thereby creating a path of direct connections that falls outside the claim scope. The Plaintiff's theory appears to be that bypassing the pre-defined category hierarchy constitutes the claimed invention.
• Technical Questions: The infringement theory hinges on whether the accused website operates by "associating" nodes with "keywords" as described in the patent. A key factual question is whether the website’s search functionality performs this specific claimed method or uses a different technology, such as a standard full-text indexing engine that does not rely on a pre-defined keyword-to-node association.

V. Key Claim Terms for Construction

The Term: "jumping"

• Context and Importance: This term defines the core inventive act of bypassing the hierarchy. Its construction is critical to determining whether the accused functionality—which likely involves a user clicking a link on a search results page—infringes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes enabling a caller "to skip to the correct node(s) without having to trace through the entire path," which could be argued to encompass any mechanism that avoids manual, step-by-step traversal, including clicking a search result link (’379 Patent, col. 13:58-60).
  • Evidence for a Narrower Interpretation: The abstract states the system will "jump to that node without first traversing any other node," which may suggest a more direct, system-initiated redirection without an intervening step like displaying a list of search results for user selection (’379 Patent, Abstract).

The Term: "not directly connected"

• Context and Importance: This limitation distinguishes the claimed invention from simple navigation to the next level in a hierarchy. Its meaning will be central to whether the accused system’s architecture meets the claim. Practitioners may focus on this term because if a search result page is considered a "node" that is "directly connected" to the homepage, infringement may be avoided.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent uses hierarchical trees as its primary example (e.g., Fig. 1), where "direct connections" are the edges between parent and child nodes. Plaintiff may argue that only these pre-defined hierarchical links qualify as direct connections, and a search-generated link to a deep product page is therefore a connection to a node that is "not directly connected."
  • Evidence for a Narrower Interpretation: The patent equates connections with "edges" in a graph structure (’379 Patent, col. 2:33-35). Defendant may argue that any hyperlink from the first node (homepage) to another page (e.g., a search results page) establishes a "direct connection" via an edge, regardless of its position in the marketing-defined category hierarchy.

VI. Other Allegations

Indirect Infringement

• The complaint does not allege indirect infringement. The single count is for direct infringement under 35 U.S.C. § 271(a) (Compl. ¶16).

Willful Infringement

• The complaint does not contain an explicit allegation of willful infringement or plead facts sufficient to establish pre-suit knowledge of the patent or a risk of infringement.

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

• A threshold issue for the court is the procedural finality of the case. Given that all claims of the '379 patent were cancelled in a post-filing IPR proceeding, the central question is the legal effect of this cancellation on the complaint. The invalidation of the only asserted patent is likely dispositive.
• Assuming the case were to proceed, a core issue would be one of definitional scope: can the term "jumping" be construed to cover a standard e-commerce search process where a user types a query, reviews a results page, and clicks a link? Or does the claim require a more automated, direct system redirection?
• Finally, a key evidentiary question would be one of technical operation: does the accused United Rentals website function by using the claimed method of associating pre-defined "keywords" with specific "nodes", or does it rely on a conventional search technology that operates on different principles? The complaint's conclusory allegations would require significant factual development to substantiate this point.