GeoSymm Ventures LLC v. Luma Health Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Luma Health, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.
• Case Identification: 1:24-cv-00836, D. Del., 07/18/2024
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant has an established place of business in the district, has committed acts of infringement there, and Plaintiff has suffered harm in the district.
• Core Dispute: Plaintiff alleges that Defendant’s patient engagement and communication platform infringes a patent related to an "assistive agent" that processes user requests and interacts with various web services.
• Technical Context: The technology relates to virtual assistant frameworks that interpret natural language user requests to perform tasks by integrating with a variety of backend data sources and services via APIs.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,130,900 - "Assistive agent"

• Patent Identification: U.S. Patent No. 9,130,900, "Assistive agent", issued September 8, 2015.

The Invention Explained

• Problem Addressed: The patent asserts that prior personal information managers (PIMs) failed to "take full advantage of the information" they stored, acting as siloed applications rather than intelligent, integrated assistants that could understand context to help a user. (Compl., Ex. 1, ’900 Patent, col. 1:22-24).
• The Patented Solution: The invention describes a system and method for an "assistive agent" that receives a user request from a mobile device, determines the "semantics" of that request by identifying its domain, task, and parameters, and then accesses one or more "semantic web services" through an Application Program Interface (API) to determine and provide a responsive answer. (’900 Patent, Abstract; Fig. 2). This framework allows the agent to interact with a diverse set of external and internal services, such as calendars or third-party data sources, to fulfill complex requests. (’900 Patent, col. 4:25-43).
• Technical Importance: The described technology provides a framework for creating more powerful and context-aware virtual assistants that can orchestrate multiple services to perform tasks, a shift from simple command execution to more integrated, intent-based computing. (’900 Patent, col. 1:47-53).

Key Claims at a Glance

• The complaint alleges infringement of "exemplary claims" without specifying them. (Compl. ¶11). The patent contains three independent claims (1, 19, and 20). Claim 1 is the broadest method claim.
• Independent Claim 1 recites a method with the following essential elements:
  • receiving a user request for assistance from a mobile device;
  • determining semantics of the user request by parsing it to identify representations of meaning or interpretation, along with location and personal information captured by the mobile device (including telephone, texting, and user activity);
  • accessing one or more semantic web services via an API to retrieve matching data;
  • identifying, generating, or providing personalized recommendations;
  • presenting possible responses by interacting with the web services and confirming user responses by accessing a text messaging or phonebook API;
  • determining a responsive answer; and
  • responding to the user.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to infringement of "one or more claims." (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" but incorporates the specific product list and functionality descriptions in an exhibit (Exhibit 2) that was not attached to the publicly filed complaint. (Compl. ¶11, ¶16). Based on the defendant’s identity, the accused products are presumably part of the Luma Health Patient Success Platform™.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context, as these details are contained within the missing Exhibit 2. (Compl. ¶16-17).

IV. Analysis of Infringement Allegations

The complaint incorporates claim charts by reference in its Exhibit 2, which is not available for analysis. (Compl. ¶16-17). Therefore, a detailed element-by-element comparison is not possible. The infringement theory must be inferred from the patent claims and the general allegations. Plaintiff’s theory appears to be that Defendant's platform functions as an "assistive agent" by receiving requests (e.g., from healthcare providers or patients), determining the intent of those requests (e.g., to schedule an appointment), and accessing various backend services via APIs to fulfill the requests, thereby practicing the patented method.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The patent describes a general-purpose "assistive agent" with examples like finding restaurants or playing music. (’900 Patent, col. 9:43-44; col. 11:26-28). A primary point of contention may be whether the claims, and particularly their use of broad terms, can be read to cover a specialized platform operating in the distinct technical field of healthcare patient management.
  • Technical Questions: Claim 1 requires "determining semantics... by parsing the user request... along with location and user personal information captured by the mobile device including telephone, texting, and user activity." (’900 Patent, col. 27:60-65). A key question will be whether the complaint provides evidence that the accused platform performs this specific type of semantic analysis using this combination of data sources, or if it uses a different, non-infringing method to process requests.

V. Key Claim Terms for Construction

• The Term: "semantic web services"

  • Context and Importance: This term is central to the claimed invention, as it defines the entire ecosystem of services with which the "assistive agent" interacts. The construction of this term—whether it is limited to a specific technical standard or covers any API-accessible service—will be critical to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides examples of "semantic web services" that include general consumer services like "Facebook, Amazon, Yahoo, eBay, and the like sources" as well as applications on the device itself, such as "an alarm application ('app'), contacts, calendar, or the like." (’900 Patent, col. 4:32-34, col. 4:41-43). This language may support a broad definition covering any service accessible via an API.
    • Evidence for a Narrower Interpretation: The "semantic web" is a technical field with specific standards. The specification explicitly mentions "Resource Description Framework (RDF)" and "e web ontology language," which are core components of the semantic web. (’900 Patent, col. 13:19-22). A party could argue the term should be limited to services that utilize these specific semantic technologies, potentially excluding standard REST APIs.

• The Term: "determining semantics of the user request"

  • Context and Importance: This phrase describes the core intelligence of the claimed agent. Practitioners may focus on this term because the dispute will likely turn on whether the accused platform's method for understanding user input matches the specific method required by the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes this step as identifying "at least one domain, at least one task, and at least one parameter for the user request." (’900 Patent, col. 27:58-60). This could be interpreted broadly to cover any system that categorizes user intent.
    • Evidence for a Narrower Interpretation: Claim 1 links the "determining semantics" step to a specific set of inputs: parsing the request "along with location and user personal information captured by the mobile device including telephone, texting, and user activity." (’900 Patent, col. 27:61-65). This language may support a narrower construction requiring the use of these specific data sources, which may not be present in the accused system.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant provides "product literature and website materials" that direct end users to use its products in a manner that infringes the ’900 Patent. (Compl. ¶14).
• Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after gaining "actual knowledge" of the patent and the infringement allegations from the service of the complaint. (Compl. ¶13-14).

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

• A core issue will be one of definitional scope: can the term "semantic web services," which has specific technical origins, be construed broadly enough to read on the various backend systems and APIs integrated into Defendant's specialized patient engagement platform?
• A key evidentiary question will be one of technical implementation: does the accused platform perform the claimed step of "determining semantics" by parsing user requests in combination with the specific data sources recited in Claim 1, such as "telephone, texting, and user activity" from a mobile device, or is there a fundamental mismatch in the operational methods?