DCT

1:24-cv-00834

GeoSymm Ventures LLC v. Bitonic Technology Labs Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-00834, D. Del., 04/03/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant has an established place of business in the district, has allegedly committed acts of infringement there, and Plaintiff has suffered harm in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s virtual assistant products infringe a patent related to a system and method for providing automated assistance by parsing a user's request and integrating it with external semantic web services.
  • Technical Context: The technology concerns the architectural design of virtual assistants, specifically how they interpret natural language requests and interact with various web-based services to provide context-aware responses.
  • Key Procedural History: The currently operative complaint is a First Amended Complaint. The complaint alleges that Defendant has had actual knowledge of the patent and its alleged infringement since at least July 18, 2024, the filing date of the Original Complaint.

Case Timeline

Date Event
2013-03-15 ’900 Patent Priority Date
2015-09-08 ’900 Patent Issue Date
2024-07-18 Original Complaint Filing Date
2025-04-03 First Amended Complaint Filing Date

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

U.S. Patent No. 9,130,900 - “Assistive agent,” issued September 8, 2015

The Invention Explained

  • Problem Addressed: The patent asserts that prior art virtual assistants and personal information managers (PIMs) were inefficient because they relied on "segregated data sources that operated independently" (Compl. ¶10; ’900 Patent, col. 1:21-23). These systems lacked deep integration and personalized context awareness, forcing users to manually manage complexities like setting reminder lead times and failing to "take full advantage of the information available to them" (’900 Patent, col. 1:29-31; Compl. ¶11).
  • The Patented Solution: The invention proposes a system architecture for an "assistive agent" that improves upon prior art by first determining the "semantics" of a user's request—identifying a specific domain, task, and parameters—before accessing external services (’900 Patent, Abstract). This unified approach allows the system to integrate various data sources and "balance the apparent considerations...in a consistent manner" to provide relevant output, thereby improving efficiency and contextual relevance (’900 Patent, col. 3:5-8; Compl. ¶14).
  • Technical Importance: The claimed architecture sought to enhance computer functionality by operationalizing a user's semantic intent into an efficient strategy for using online services, which allegedly reduced redundant service calls, minimized network traffic, and improved response time compared to earlier systems (Compl. ¶¶16, 20).

Key Claims at a Glance

  • The complaint focuses its allegations on at least Claim 1 of the ’900 Patent (Compl. ¶¶13, 21).
  • The essential elements of independent Claim 1 include:
    • Receiving a user request for assistance from a mobile device.
    • Determining semantics of the user request by identifying at least one domain, task, and parameter by parsing the request to identify its meaning along with location and personal information (e.g., telephone, texting, user activity) captured by the device.
    • Accessing one or more semantic web services through an Application Program Interface (API) to retrieve data matching the identified domain, task, and parameter.
    • Presenting possible responses to the user by interacting with the semantic web services.
    • Determining a responsive answer.
    • Responding to the user request.
  • The complaint broadly alleges infringement of "one or more claims" without specifying additional claims (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as the "Exemplary Defendant Products," which are detailed in claim charts attached as Exhibit 2 (Compl. ¶¶24, 29). This exhibit was not filed with the public complaint.

Functionality and Market Context

The complaint alleges that the accused products are virtual assistant systems that directly infringe the ’900 Patent by making, using, selling, or importing technology that practices the claimed methods (Compl. ¶24). It is alleged that Defendant's employees also internally test and use these products (Compl. ¶25). The complaint asserts that Defendant distributes "product literature and website materials" which induce end users to operate the products in an infringing manner (Compl. ¶27). The complaint does not provide sufficient detail for analysis of the products' specific market context or commercial importance.

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibit 2 to support its infringement allegations, but this exhibit is not publicly available (Compl. ¶¶29-30). The infringement theory must therefore be summarized from the complaint’s narrative allegations.

The core of the infringement theory is that the "Exemplary Defendant Products" embody the "novel architectural framework" of the ’900 Patent (Compl. ¶20). Plaintiff alleges that Defendant’s products practice the claimed method by receiving a user request and performing "semantic intent determination" before accessing external web services (Compl. ¶20). This allegedly involves parsing the request to identify a "domain," "task," and "parameter" and then using that semantic understanding to access appropriate "semantic web services" via an API (Compl. ¶21). The complaint contends this architecture, which integrates contextual data like location and user history, allows Defendant's products to achieve the same technical benefits described in the patent, such as optimized service selection and reduced processing overhead (Compl. ¶¶16, 20).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: A central dispute may concern the scope of "semantic web services" (’900 Patent, Claim 1). The question is whether this term, as used in the patent, is limited to services that employ formal ontologies (e.g., RDF, as discussed in the specification), or if it can be read more broadly to cover any modern, API-accessible web service providing structured data.
  • Technical Questions: A key evidentiary question will be whether the accused products' internal architecture performs the specific step of "determining semantics of the user request...by parsing the user request to identify representations of meaning or interpretation" as required by Claim 1. The dispute may focus on whether the accused system's natural language processing is functionally equivalent to the patent's described multi-layered architecture involving a "grammatical analyzer" and an "ontology" (’900 Patent, col. 9:10-13, Fig. 7).

V. Key Claim Terms for Construction

"semantic web services"

Context and Importance

The definition of this term is critical, as it defines the universe of external technologies with which the claimed method interacts. Its construction will determine whether the services accessed by Defendant's products fall within the scope of the claims.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification provides examples of third-party service providers such as "Facebook, Amazon, Yahoo, eBay, and the like sources," which may suggest a broad, functional definition not tied to a specific underlying technology (’900 Patent, col. 4:31-34).
  • Evidence for a Narrower Interpretation: The specification also explicitly mentions technologies like "Resource Description Framework (RDF)" and "web ontology language" in the context of the services (’900 Patent, col. 13:19-22). The detailed discussion of an "Active Ontology" (Fig. 7) could be used to argue that "semantic web services" are limited to those employing such formal, structured semantic technologies.

"determining semantics of the user request"

Context and Importance

Practitioners may focus on this term because it describes the core inventive step that allegedly distinguishes the patent from prior art. The central infringement question is whether Defendant's technology performs this specific type of analysis or a more conventional form of natural language processing.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The language in Claim 1, "parsing the user request to identify representations of meaning or interpretation," could be argued to encompass a variety of modern NLP techniques that extract user intent from text or speech (’900 Patent, Claim 1).
  • Evidence for a Narrower Interpretation: The patent describes a specific "multi-layered semantic processing pipeline" that places "semantic intent determination at the center of the system's design" (Compl. ¶20). The specification details a "grammatical analyzer" and interaction with a "semantic database" or "ontology," which a party could argue narrows the claim to a system with that specific, unconventional architecture (’900 Patent, col. 9:8-13, 9:50-51, Fig. 7).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that Defendant provides "product literature and website materials" that instruct and encourage end users to operate the accused products in a manner that directly infringes the ’900 Patent (Compl. ¶¶27, 28).

Willful Infringement

The complaint alleges that Defendant has had "actual knowledge of infringement" since at least the date the original complaint was filed, July 18, 2024 (Compl. ¶26). It is alleged that Defendant’s continued infringing activities after this date are willful (Compl. ¶27).

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

  1. A core issue will be one of definitional scope: can the term "semantic web services", which the patent links to formal ontologies like RDF, be construed broadly enough to cover the modern, general-purpose APIs likely used by the accused products?
  2. A key evidentiary question will be one of architectural equivalence: what evidence will be presented to demonstrate that the accused products’ internal software architecture performs the specific, multi-step process of "determining semantics" as described in the patent, rather than a more conventional NLP workflow?
  3. The viability of the inducement claim will depend on whether the unspecified "product literature and website materials" contain specific instructions that would lead a user to perform every step of the asserted method claim.