Guada Tech LLC v. Decathlon USA LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Guada Technologies LLC (Texas)
  • Defendant: Decathlon USA LLC (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm
• Case Identification: 1:20-cv-00868, D. Del., 06/28/2020
• Venue Allegations: Venue is alleged in the District of Delaware on the basis that Defendant is a Delaware limited liability company.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to navigating hierarchical data structures by allowing users to "jump" to non-adjacent destinations using keyword-based searches.
• Technical Context: The technology addresses inefficiencies in navigating menu-driven systems by supplementing traditional, step-by-step navigation with a method for direct access to deeper-level options based on keyword matching.
• Key Procedural History: The complaint notes that the patent-in-suit was cited as prior art during the prosecution of other patents. Significantly, subsequent to the filing of this complaint, an Inter Partes Review (IPR) Certificate was issued for the patent-in-suit, reflecting the outcome of IPR proceedings IPR2021-00875 and IPR2022-00217. The certificate states that all claims of the patent, including the one asserted in the complaint, have been cancelled. This post-filing development raises a fundamental question about the viability of the infringement action.

Case Timeline

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

• 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 problem of navigating hierarchical networks of choices, such as automated telephone menus or computer file systems, as potentially frustrating and inefficient for users (Compl. ¶13; ’379 Patent, col. 2:9-18). Conventional systems often require users to traverse the hierarchy level by level, making it difficult to correct a wrong turn or reach a desired destination quickly ('379 Patent, col. 2:9-18).
  • The Patented Solution: The invention proposes a method to make navigation more efficient by allowing a user to "jump" from one point (a "node") in the hierarchy to another, non-adjacent node ('379 Patent, col. 3:30-34). This is achieved by associating nodes with keywords. When a user provides an input containing a keyword, the system can identify the associated node and navigate directly to it, bypassing the intermediate hierarchical steps (Compl. ¶14; ’379 Patent, col. 3:35-43). The patent's Figure 1, reproduced in the complaint, illustrates a generic hierarchical network of nodes that the invention is designed to navigate (Compl. p. 4).
  • Technical Importance: This approach aimed to improve user experience in complex menu-driven systems by providing a more direct and intuitive navigation path, moving beyond rigid, sequential traversal ('379 Patent, col. 2:22-30).
• Key Claims at a Glance:
  • The complaint asserts infringement of at least independent claim 1 ('Compl. ¶16).
  • The essential elements of independent 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.
  • The prayer for relief indicates Plaintiff may assert other claims ('Compl. p. 7, ¶a).

III. The Accused Instrumentality

• Product Identification: The website https://www.decathlon.com/ and its associated subsites, web pages, and functionality (the "Accused Instrumentality") ('Compl. ¶16).
• Functionality and Market Context: The complaint alleges the Accused Instrumentality is an e-commerce website that utilizes a hierarchical arrangement for its product categories (e.g., "Women," then "Tops," then "Sweatshirt/Hoodies") ('Compl. ¶16). It is alleged to have a search box on its home page that accepts user input. The complaint asserts that when a user enters a search term like "women's sweatshirt," the website identifies a related product and "allows jumping to those items/nodes without traversing preceding generic category nodes," thereby infringing the patented method ('Compl. ¶16).

IV. Analysis of Infringement Allegations

'379 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question is whether the components of a modern e-commerce website map to the claimed elements. Specifically, can a product category page or a specific product page be considered a "node" in a "hierarchical arrangement" as contemplated by the patent? Furthermore, does displaying a page of search results constitute "jumping to the at least one node," or is it a distinct technical operation?
  • Technical Questions: What evidence does the complaint provide that the accused website's search function operates by identifying a "node" that is "associated with the at least one keyword" in the manner described by the patent? The complaint's allegations are conclusory and do not detail the underlying mechanism, which may differ from the patent's teachings of using an inverted index or similar structure to link keywords to pre-defined nodes.

V. Key Claim Terms for Construction

• The Term: "node"

• Context and Importance: The entire method is predicated on navigating between "nodes." The complaint equates website categories and product pages to "nodes" ('Compl. ¶16). The construction of this term will determine whether the patent's framework can be applied to the accused website architecture. Practitioners may focus on this term because its definition is fundamental to the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent specification describes "nodes" generally as representing "a specific choice or option in the hierarchy" ('379 Patent, col. 4:25-27) and as vertices in a graph structure ('379 Patent, col. 2:32-34), language that could support application to various digital structures, including web pages.
  • Evidence for a Narrower Interpretation: Many of the patent's specific examples relate to more formally structured, discrete choice systems like interactive voice response (IVR) systems ('379 Patent, Fig. 6) and interactive television program guides ('379 Patent, Fig. 4). This could support a narrower construction limited to systems with a more rigid, pre-defined tree structure than a dynamic website.

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

• Context and Importance: This phrase describes the core infringing act. The dispute may turn on whether displaying a dynamically generated search results page is equivalent to the claimed "jumping."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent uses the term "jump" to describe its solution broadly, such as allowing a system to "'jump' laterally from one branch to another" ('Compl. ¶14; '379 Patent, col. 3:35-37). This may support an interpretation that covers any form of non-sequential navigation initiated by a keyword search.
  • Evidence for a Narrower Interpretation: The specification discusses "jumping" in the context of "avoiding the need to traverse intervening nodes" ('379 Patent, col. 5:17-20). A party could argue this implies navigation between two pre-existing points within a static hierarchy, rather than the generation of a new search results page that did not exist as a "node" prior to the user's query.

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

1. A central, and likely dispositive, issue is one of viability: given that the USPTO cancelled all claims of the '379 patent in an inter partes review proceeding subsequent to the filing of the complaint, what legal basis remains for Plaintiff's infringement action? The case appears to be asserted on a patent that is no longer enforceable.
2. Should the case proceed, a core question will be one of definitional scope: can the patent's terminology, such as "node" and "jumping," which is described in the context of structured decision trees like IVR systems, be construed to read on the architecture and functionality of a modern, dynamic e-commerce website and its search function?
3. A key evidentiary question will be whether the accused website's search functionality operates in a manner technically equivalent to the method claimed in the patent. The analysis will require evidence showing not just a similar outcome (finding a product via search) but a similar process (identifying a pre-defined, non-adjacent "node" associated with a keyword and navigating to it).