Ridgeview IP LLC v. Cornerstone OnDemand Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ridgeview IP LLC (Texas)
  • Defendant: Cornerstone OnDemand, Inc. (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA
• Case Identification: 1:22-cv-00558, D. Del., 04/28/2022
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified software products infringe a patent related to methods for displaying database search results to a user.
• Technical Context: The technology concerns user interfaces for database searching that guide a user by dynamically updating available search terms and operators to proactively prevent queries that would yield no results.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2001-01-24	U.S. Patent No. 6,983,270 Priority Date
2006-01-03	U.S. Patent No. 6,983,270 Issued
2022-04-28	Complaint Filed

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

U.S. Patent No. 6,983,270 - "Method and apparatus for displaying database search results"

• Patent Identification: U.S. Patent No. 6,983,270, "Method and apparatus for displaying database search results," issued January 3, 2006.

The Invention Explained

• Problem Addressed: The patent addresses the common user frustration of conducting a database search (e.g., using Boolean operators like "AND") only to receive a "null result" or "no documents found" message, without guidance on how to successfully reformulate the query (’270 Patent, col. 2:2-15).
• The Patented Solution: The invention describes a method where the search interface interactively guides the user. After a user selects a first search term, the system automatically "audits" the remaining options and updates the user interface to display only those subsequent terms and logical operators (e.g., "AND", "NOT") that are guaranteed to produce a non-null, or "valid," result (’270 Patent, col. 3:1-14, FIG. 6). This process repeats with each user selection, dynamically narrowing the available choices to prevent the user from constructing a dead-end query.
• Technical Importance: This approach aimed to simplify the database search process by making it impossible for a user to construct a query that fails, thereby improving user experience without requiring complex correlation software or a pre-existing query history (’270 Patent, col. 2:8-15).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶11).
• The essential elements of independent claim 1 include:
  • Displaying a set of entries and a set of operators from a database.
  • Selecting an initial entry.
  • Updating the displayed set of operators to only include those that can produce a valid result with the selected entry.
  • Selecting an operator from the updated set.
  • Updating the displayed set of entries to only include those that can produce a valid result when combined with the already selected entry and operator.
  • Selecting a new entry from the updated set.
  • Updating the displayed set of valid results.
  • Repeating the process until a desired result is achieved.
• The complaint notes that infringement is alleged literally or under the doctrine of equivalents (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11, ¶13).

Functionality and Market Context

• The complaint does not describe the specific functionality or market context of the accused products. It alleges that the products "practice the technology claimed by the '270 Patent" and states that a comparison is provided in an external "Exhibit 2" which is referenced but not included with the complaint (Compl. ¶13-14). The complaint does not provide sufficient detail for analysis of the accused products' specific functionality.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" directly infringe claim 1 of the ’270 Patent (Compl. ¶11). The pleading states that "Exhibit 2 includes charts comparing claim 1 of the’270 Patent to the Exemplary Defendant Products" and that these charts demonstrate that the products "satisfy all elements of claim 1" (Compl. ¶13). However, this Exhibit 2 is not attached to or included within the complaint document itself. Therefore, a detailed element-by-element analysis based on the plaintiff's specific allegations is not possible from the face of the complaint. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may concern the scope of the term "updating." The patent requires updating both the list of available operators and the list of available entries to proactively eliminate choices that would lead to a null result. The question for the court will be whether any filtering or sorting functionality in the accused products performs this specific, pre-emptive exclusionary function, or if it operates in a technically distinct manner.
  • Technical Questions: A key evidentiary question will be whether the accused products perform the specific, sequential, and iterative process mandated by claim 1 (select entry -> update operators -> select operator -> update entries -> ...). The complaint provides no factual allegations detailing how a user's interaction with the accused products maps to this claimed sequence.

V. Key Claim Terms for Construction

• The Term: "valid result"

  • Context and Importance: This term is foundational to the patent's purpose of avoiding "nullity." Infringement will depend on whether the output of the accused products meets the definition of a "valid result." Practitioners may focus on this term because its definition dictates the goal of the entire claimed process.
  • Intrinsic Evidence for a Broader Interpretation: Claim 1(f) requires updating the displayed entries so that a subsequent query will "produce at least one valid result," which could support a broad interpretation where any non-null (i.e., not empty) result set is considered "valid" (’270 Patent, col. 12:1-3).
  • Intrinsic Evidence for a Narrower Interpretation: The specification distinguishes the invention from prior art that produces "irrelevant terms" and aims to avoid "unwanted" results, suggesting "valid" could imply a higher standard than merely "not empty," such as being contextually relevant (’270 Patent, col. 2:15-17). Furthermore, claim 5, which corresponds to a "desired result" of "a nullity," complicates a simple "non-null" definition for "valid result" (’270 Patent, col. 12:20-22).

• The Term: "updating said set of displayed entries in response to the selected operator"

  • Context and Importance: This limitation describes the core technical mechanism of the invention. The infringement case will likely hinge on whether the accused products perform an "update" that is functionally equivalent to the specific process described in the patent.
  • Intrinsic Evidence for a Broader Interpretation: A party could argue that any re-sorting, re-ordering, or filtering of a list of potential search terms after a user selects a logical operator constitutes an "update" in a general sense.
  • Intrinsic Evidence for a Narrower Interpretation: The patent describes this step as an "auditing step that audits or scans all possible response terms and eliminates the irrelevant and impossible responses" (’270 Patent, col. 3:7-10). Claim 1 links this update to the specific outcome of enabling the production of "at least one valid result," suggesting the update must be a pre-emptive, exclusionary filter, not just a generic re-display of information (’270 Patent, col. 11:65-12:3).

VI. Other Allegations

• Indirect Infringement: The complaint does not plead facts supporting, or make a formal claim for, indirect infringement. It alleges direct infringement by Defendant and through the internal testing and use of the products by Defendant's employees (Compl. ¶11-12).
• Willful Infringement: The complaint does not contain an explicit count for willful infringement or plead facts related to pre-suit knowledge. However, the prayer for relief requests a judgment awarding "all appropriate damages under 35 U.S.C. § 284" and asks the court to declare the case "exceptional within the meaning of 35 U.S.C. § 285," which are remedies available for findings of willful or otherwise egregious infringement (Compl. ¶IV(D)-(E)).

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

• A central issue will be one of evidentiary sufficiency: as the complaint outsources its infringement theory to an unprovided exhibit, the case will depend on what specific evidence Plaintiff can later produce to show that the accused products actually perform the iterative, guided search sequence of claim 1, particularly the pre-emptive elimination of search options that would lead to a null result.
• The dispute may also turn on a question of definitional scope: can the claimed process of "updating... to produce at least one valid result" be construed to read on the general-purpose filtering or search-suggestion features common in modern software, or is there a fundamental mismatch between such features and the specific null-avoidance logic required by the patent?