DCT

1:23-cv-01030

AlphaSense Oy v. Tegus Inc

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Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-01030, D. Del., 09/21/2023
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because both Defendants are incorporated in Delaware and therefore reside in the district.
  • Core Dispute: Plaintiff alleges that Defendants’ financial document search platforms infringe six patents related to user interfaces and systems for searching, analyzing, and displaying information from financial documents.
  • Technical Context: The technology at issue involves specialized search engines for the financial industry, designed to improve the speed and precision with which analysts can extract relevant insights from vast collections of corporate filings and transcripts.
  • Key Procedural History: The complaint notes that Tegus acquired Bamsec in 2021 and subsequently integrated elements of the Bamsec Platform into the Tegus Platform. It also alleges that during the prosecution of the patents-in-suit and related patents, the U.S. Patent and Trademark Office confirmed the patent eligibility of the claimed inventions.

Case Timeline

Date Event
2009-11-03 Priority Date for all six Patents-in-Suit
2010-01-01 AlphaSense Platform launched
2013-01-01 Bamsec Platform launched
2017-01-01 Tegus Platform launched
2021-01-01 Tegus acquires Bamsec
2022-01-04 ’164 Patent Issued
2022-02-08 ’273 Patent Issued
2022-03-22 ’739 Patent Issued
2023-01-10 ’453 Patent Issued
2023-06-27 ’218 Patent Issued
2023-07-18 ’006 Patent Issued
2023-09-21 Complaint Filed

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

U.S. Patent No. 11,216,164

  • Patent Identification: U.S. Patent No. 11,216,164, “Server With Associated Remote Display Having Improved Ornamentality and User Friendliness for Searching Documents Associated With Publicly Traded Companies,” issued January 4, 2022 (the “’164 Patent”).
  • The Invention Explained:
    • Problem Addressed: The patent’s background section describes the inefficiency of conventional web search engines for financial analysts, which return links to entire documents and require users to "spend endless amounts of time clicking through those documents" (Compl. ¶29; ’164 Patent, col. 1:18-27). These traditional engines also lack the ability to conduct searches based on sentiment (positive/negative) or tense (past/future) (Compl. ¶27; ’164 Patent, col. 1:40-51).
    • The Patented Solution: The invention is a search system that, in response to a user query, identifies relevant financial documents and renders a user interface with three key components: a list of the identified documents, a list of "complete sentence snippets" from a selected document that contain the search keywords, and a view of a selected snippet within its surrounding text in the original document (Compl. ¶26; ’164 Patent, Abstract, col. 15:20-42). This multi-panel display is intended to allow for rapid scanning and contextual understanding without reading the entire source document (Compl. ¶32; ’164 Patent, col. 12:67-13:2).
    • Technical Importance: This approach aims to accelerate financial research by presenting discrete, context-rich sentences as the primary search result, rather than just links to full documents (Compl. ¶26).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 10 (Compl. ¶65).
    • Claim 10 is a system claim comprising a server operable to perform several steps, including:
      • receiving a query from a user identifying a publicly traded company and at least two distinct keywords;
      • executing a search based on the query;
      • generating search results containing "identified snippets of text" from financial documents, where the snippets "comprise a complete sentence" and are identified when the keywords appear within a "defined maximum distance"; and
      • causing to render content on a user interface that includes a list of documents, a plurality of the snippets, the text surrounding a user-selected snippet, and a stock ticker or name of the company.

U.S. Patent No. 11,244,273

  • Patent Identification: U.S. Patent No. 11,244,273, “System For Searching And Analyzing Documents In The Financial Industry,” issued February 8, 2022 (the “’273 Patent”).

  • The Invention Explained:

    • Problem Addressed: The patent addresses the same inefficiencies of conventional search for financial analysis as the ’164 Patent (Compl. ¶36; ’273 Patent, col. 1:13-47).
    • The Patented Solution: The system described is similar to that in the ’164 Patent but adds a distinct capability: identifying "recurring statements" within a selected document by comparing it to "sequential documents" (e.g., a prior quarter's financial filing). The system then displays these recurring statements "differently from statements that are not recurring," allowing a user to focus on new information (Compl. ¶93, ¶94; ’273 Patent, col. 15:1-10).
    • Technical Importance: By automatically distinguishing between new disclosures and repeated boilerplate language from previous filings, the invention seeks to further enhance the efficiency of financial analysis (Compl. ¶94).

  • Key Claims at a Glance:

    • The complaint asserts at least independent claim 7 (Compl. ¶81).
    • Claim 7 is a system claim comprising one or more processors operable to perform steps largely parallel to claim 10 of the ’164 Patent, with the addition of the following key elements:
      • identifying recurring statements in the user selected document;
      • wherein the recurring statements are identified when a statement recurs in sequential documents that are generated by the publicly traded company on a scheduled time basis; and
      • wherein the recurring statements are displayed differently from statements that are not recurring.

  • Multi-Patent Capsule: U.S. Patent No. 11,281,739

    • Patent Identification: U.S. Patent No. 11,281,739, "Computer With Enhanced File And Document Review Capabilities," issued March 22, 2022 (the “’739 Patent”) (Compl. ¶39).
    • Technology Synopsis: The patent describes a system to improve the efficiency of financial document review by presenting search results as selectable sentence snippets within a user interface. A key aspect is the system's ability to present the list of identified financial documents "grouped according to a type of financial documents" (Compl. ¶40, ¶109; ’739 Patent, claim 10).
    • Asserted Claims: At least independent claim 10 is asserted (Compl. ¶99).
    • Accused Features: The Bamsec Platform is accused of infringing by providing a user interface that groups search results by document type (e.g., "Transcripts," "News," "Financials") and displays selectable snippets from within those documents (Compl. ¶110, p. 29).

  • Multi-Patent Capsule: U.S. Patent No. 11,550,453

    • Patent Identification: U.S. Patent No. 11,550,453, "User Interface For Use With A Search Engine For Searching Financial Related Documents," issued January 10, 2023 (the “’453 Patent”) (Compl. ¶44).
    • Technology Synopsis: The patent addresses inefficient financial document search with a system that provides an interface for displaying search results. The claimed interface includes a list of documents, a plurality of selectable sentence snippets from within a selected document, and a contextual view of a selected snippet that is highlighted (Compl. ¶45; ’453 Patent, claim 10).
    • Asserted Claims: At least independent claim 10 is asserted (Compl. ¶115).
    • Accused Features: The Tegus and Bamsec Platforms are accused of infringing by employing a multi-pane user interface that renders a document list, selectable snippets, and a highlighted contextual view of a selected snippet (Compl. ¶126).

  • Multi-Patent Capsule: U.S. Patent No. 11,687,218

    • Patent Identification: U.S. Patent No. 11,687,218, "User Interface For Use With A Search Engine For Searching Financial Related Documents," issued June 27, 2023 (the “’218 Patent”) (Compl. ¶49).
    • Technology Synopsis: The patent describes a system that improves financial document search by not only executing searches but also by detecting when "one or more new documents" that match a query enter the database. In response, the system generates a "report" for the user that includes an identified snippet of text from the new document (Compl. ¶50; ’218 Patent, claim 1).
    • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶131).
    • Accused Features: The Bamsec Platform's "search alerts" feature is accused of infringing by detecting new documents that match a user's search and generating reports, such as emails, that contain snippets from those new documents (Compl. ¶144, ¶146). The complaint provides a screenshot of the "All-Company Search Alerts" interface (Compl. p. 58).

  • Multi-Patent Capsule: U.S. Patent No. 11,704,006

    • Patent Identification: U.S. Patent No. 11,704,006, "User Interface For Use With A Search Engine For Searching Financial Related Documents," issued July 18, 2023 (the “’006 Patent”) (Compl. ¶54).
    • Technology Synopsis: The technology is substantially similar to the ’218 Patent, describing a system that detects new documents matching a user's search query and, in response, generates a report for the user containing snippets from the new documents. The system is also claimed to render a highlighted portion of the new document from the report (Compl. ¶55; ’006 Patent, claim 1).
    • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶153).
    • Accused Features: The Bamsec Platform's search alert functionality is accused of infringing by detecting new documents and generating reports with snippets from them, which can then be rendered for the user (Compl. ¶164, ¶166).

III. The Accused Instrumentality

  • Product Identification: The "Bamsec Platform" and the "Tegus Platform," both described as document search technology platforms primarily for the financial services industry (Compl. ¶5, ¶6, ¶62).
  • Functionality and Market Context: The complaint alleges that the accused platforms are web- and mobile-accessible applications used for "aggregating, navigating, searching, and displaying relevant financial content and data" (Compl. ¶62, ¶63). The platforms allegedly allow users to search for keywords within a corpus of financial documents, such as SEC filings and earnings call transcripts, for a specified publicly traded company (Compl. ¶68, ¶70). The complaint alleges that the platforms present results in a multi-pane user interface that is "strikingly similar" to the Plaintiff's AS Platform, showing a list of documents, snippets from those documents, and the full-text context of a selected snippet (Compl. ¶23, ¶76). The complaint includes a side-by-side screenshot comparing the AlphaSense and BamSEC platforms to support this allegation (Compl. p. 8). The accused platforms also allegedly include a "Compare Filings" function and a "search alerts" feature (Compl. ¶94, ¶144).

IV. Analysis of Infringement Allegations

’164 Patent Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving a query from a user at a remote computer...wherein the user query includes: information identifying a publicly traded company; a first keyword...and a second keyword... The platforms' servers are configured to receive user search queries that include a company name (e.g., Apple Inc.) and two distinct keywords (e.g., "share" and "repurchase"). ¶68, ¶70 col. 15:10-17
executing a search based on the user query; The platforms' servers execute a search based on the received user query. ¶72 col. 15:18-18
generating search results...that contain identified snippets of text...wherein the identified snippets comprise a complete sentence, wherein the snippet of text is identified when the first keyword appears within a defined maximum distance from the second keyword... The platforms generate search results that include snippets of text from financial documents. The complaint alleges these snippets are complete sentences and are identified when keywords appear within a default maximum distance of, for example, 10 words. A screenshot shows search results for "share repurchase" from an Apple Inc. earnings call transcript (Compl. p. 24). ¶74 col. 15:19-27
causing to render, on a viewing portion of the user interface, content...wherein the rendered content includes: a list of identified financial documents...a plurality of the identified snippets...text surrounding and containing a user selected snippet...and a stock ticker or a name of the publicly traded company. The platforms render content in a multi-pane user interface that allegedly includes a list of financial documents (left pane), a plurality of selectable snippets (middle pane), and the surrounding text of a selected snippet (right pane), along with the company's name. A screenshot of the Bamsec interface shows these alleged components (Compl. p. 27). ¶76 col. 15:28-42
  • Identified Points of Contention:
    • Scope Questions: Claim 10 requires rendering "text surrounding and containing a user selected snippet." A question for the court may be whether the accused platform's three-pane view, which displays the full document text on the right and highlights the selected snippet, meets this limitation, or if it simply displays the full document rather than a more narrowly defined "text surrounding" the snippet.
    • Technical Questions: The claim requires identifying a snippet when keywords appear within a "defined maximum distance." The complaint alleges this is met by a "default number of words such as 10" that "may be configurable" (Compl. ¶74). An evidentiary question will be whether the accused platforms actually perform this proximity-based identification and whether this functionality is fixed or meets the claim's implicit requirement of being definable.

’273 Patent Infringement Allegations

Claim Element (from Independent Claim 7) Alleged Infringing Functionality Complaint Citation Patent Citation
...generating search results in response to executing the search... The platforms are alleged to perform the same search and rendering functions as described in Section IV for the ’164 Patent. ¶83-92 col. 14:27-45
identifying recurring statements in the user selected document, The platforms are alleged to meet this element through a "Compare Filings" function. ¶94 col. 15:1-1
wherein the recurring statements are identified when a statement recurs in sequential documents that are generated by the publicly traded company on a scheduled time basis, The "Compare Filings" function allegedly identifies recurring statements by comparing a document to sequential documents, such as prior quarterly filings. ¶94 col. 15:2-5
wherein the recurring statements are displayed differently from statements that are not recurring. The "Compare Filings" function allegedly displays recurring (unchanged) text differently from non-recurring (added or deleted) text, for example, by using different colors or highlighting. A screenshot illustrates this alleged functionality (Compl. p. 37). ¶94 col. 15:6-8
  • Identified Points of Contention:
    • Scope Questions: Claim 7 recites a unified system that performs a search and then identifies and displays recurring statements. A question for the court may be whether the accused "Compare Filings" feature, which the complaint's evidence suggests is a separate tool for comparing two documents side-by-side, can be said to infringe a claim for an integrated search-and-display system.
    • Technical Questions: The claim requires "identifying recurring statements in the user selected document." An evidentiary question will be whether the accused feature performs an analysis within a single document to identify recurring text (based on its history), or if it simply performs a textual difference analysis between two separate, user-selected documents, which may represent a functional mismatch with the claim language.

V. Key Claim Terms for Construction

U.S. Patent No. 11,216,164

  • The Term: "snippet of text ... compris[ing] a complete sentence"
  • Context and Importance: This term is central to distinguishing the invention from prior art search tools that might display only fragmented keywords in context. Infringement will depend on whether the text excerpts displayed by the accused platforms meet this grammatical and structural requirement. Practitioners may focus on this term because it defines the fundamental unit of information presented to the user.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes the goal as allowing a user to "rapidly review a long document... and quickly see sentences in the document" (’164 Patent, col. 12:67-13:1). This focus on function might support an interpretation where any text block that conveys a complete thought, even if not perfectly grammatical, could be considered a "complete sentence."
    • Evidence for a Narrower Interpretation: The claim language is precise. The detailed description consistently refers to "complete sentence snippets" and the process of splitting a document into "sentences" using punctuation and other heuristics, suggesting a formal, grammatically defined meaning was intended (’164 Patent, col. 6:1-10, col. 9:22).

U.S. Patent No. 11,244,273

  • The Term: "identifying recurring statements in the user selected document"
  • Context and Importance: This limitation defines the novel feature of the ’273 Patent over other patents in the family. The infringement case for this patent hinges on whether the accused "Compare Filings" function meets this limitation. The dispute will likely focus on whether a tool that compares two distinct documents can be said to identify statements "in" a single "user selected document."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent’s objective is to separate "unique, meaningful information... from recurring or other boilerplate information" (’273 Patent, col. 3:54-57). An argument could be made that any feature achieving this functional goal, including a two-document comparison tool, falls within the scope of the invention.
    • Evidence for a Narrower Interpretation: The claim language specifies the identification occurs "in the user selected document." This points toward an intrinsic analysis of a single document that has been tagged with historical data, rather than an extrinsic comparison between two separate documents. The specification describes a process of identifying and tagging recurring statements as part of the initial document ingestion process, which supports this narrower reading (’273 Patent, col. 5:53-61).

VI. Other Allegations

  • Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement. It makes a general allegation of infringement under 35 U.S.C. § 271(a) but does not plead specific facts to support claims for inducement or contributory infringement, such as knowledge or intent based on user manuals, marketing materials, or other evidence (Compl. ¶59).

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

  • A core issue will be one of functional implementation: do the distinct features of the accused platforms—specifically the primary search interface, the separate "Compare Filings" tool, and the "Search Alerts" function—each map directly onto the integrated system claims of the various patents? The case may turn on whether these are considered discrete, non-infringing tools or components of a single, infringing system that meets all claim limitations.
  • A second key issue will be one of claim scope and differentiation: the six asserted patents claim closely related subject matter, with significant overlap in the core user interface and search functionality described. A central question for the court will be to construe the claims to maintain their individual validity and scope, particularly distinguishing the ’164 Patent from the ’453 Patent and the ’218 Patent from the ’006 Patent, which on their face appear to cover very similar inventions. This will be critical for both infringement and any potential damages calculations.