DCT

1:25-cv-00514

Accusearch Tech LLC v. Google LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00514, D. Del., 07/11/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Google LLC is a Delaware corporation and therefore resides in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Google LLC Search engine infringes four patents related to analyzing, annotating, and filtering internet search results to indicate when a resulting webpage is missing one or more of the user's search terms.
  • Technical Context: The technology concerns improvements to graphical user interfaces for internet search engines, designed to enhance user efficiency by providing foreknowledge about the content of linked webpages directly on the search results page.
  • Key Procedural History: The complaint does not mention prior litigation or administrative challenges involving the Asserted Patents. It does, however, dedicate substantial sections to arguing for the patent eligibility of the claims under 35 U.S.C. § 101, referencing Google LLC’s own arguments to the USPTO in prosecuting its own patents related to search technology, suggesting Plaintiff anticipates this will be a central issue in the case.

Case Timeline

Date Event
2011-06-17 Earliest Patent Priority Date
2012-12-12 Google LLC allegedly previews search result annotations showing strikethrough on missing terms
2013-12-XX Google LLC allegedly deploys "Missing:" annotations on its search results page
2020-03-10 U.S. Patent No. 10,585,959 Issued
2020-12-15 U.S. Patent No. 10,867,001 Issued
2021-08-24 U.S. Patent No. 11,100,184 Issued
2024-04-30 U.S. Patent No. 11,971,937 Issued
2025-07-11 Complaint Filed

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

U.S. Patent No. 10,585,959 - “Internet Search Results Annotation and Filtering for Missing Search Terms”

  • Patent Identification: U.S. Patent No. 10,585,959, titled “Internet Search Results Annotation and Filtering for Missing Search Terms,” issued March 10, 2020 (the “’959 Patent”). (Compl. ¶148).

The Invention Explained

  • Problem Addressed: The patent’s background describes a problem where internet search engines frequently returned results linking to webpages that did not contain all of the user's specified search terms, forcing users to waste time and bandwidth by clicking on irrelevant links to verify their content. (Compl. ¶47; ’959 Patent, col. 2:9-34).
  • The Patented Solution: The invention proposes a method to analyze the webpages referenced in search results to determine if they are missing any of the user's search terms. This information is then used to "automatically annotate" the search result on the results page itself, providing the user with "foreknowledge of the contents of these webpages" before they click a link. (Compl. ¶65; ’959 Patent, col. 2:52-3:3). The system can be implemented in various architectures, including on the user's device, a third-party server, or by the search engine provider itself. (’959 Patent, Fig. 2).
  • Technical Importance: The described solution aimed to improve the precision and efficiency of internet searching by reducing wasted clicks and providing users faster insight into the relevance of search results. (Compl. ¶65).

Key Claims at a Glance

  • The complaint asserts at least independent claim 11. (Compl. ¶320).
  • The essential elements of claim 11 are:
    • Receiving a search request comprising one or more search term elements;
    • Causing an Internet search to be performed based on the request;
    • Transmitting information comprising at least one "automatically annotated" Internet search result for display on a search results webpage;
    • Providing the annotated result as a "search result grouping" that includes an "annotation" and at least a title, link, excerpt, or URL;
    • The annotation is provided in response to a "presence or absence" of the search term elements in the referenced webpage;
    • The annotation is "automatically placed" in the search result grouping; and
    • The annotation comprises one or more "missing" search term elements and "provides an indication that the automatically annotated Internet search result is less relevant."
  • The complaint also narratively discusses dependent claims 12 (concerning descendant webpages) and 16 (concerning a selectable filtering function). (Compl. ¶154, ¶155).

U.S. Patent No. 10,867,001 - “Internet Search Results Annotation for Search Term Elements Present or Absent in Referenced Webpages and Descendant Webpages”

  • Patent Identification: U.S. Patent No. 10,867,001, titled “Internet Search Results Annotation for Search Term Elements Present or Absent in Referenced Webpages and Descendant Webpages,” issued December 15, 2020 (the “’001 Patent”). (Compl. ¶185).

The Invention Explained

  • Problem Addressed: As with the related ’959 Patent, the technology addresses the inefficiency and user frustration caused by search results that do not contain the user's specified keywords, leading to wasted time. (Compl. ¶189; ’001 Patent, col. 2:9-41).
  • The Patented Solution: The invention describes a method to "warn the user" when a search result's referenced webpage is missing one or more search terms. It involves generating an "annotation for the Internet search result" that is "comprised of a text representing the at least one search term element that is missing" and displaying it within or adjacent to the search result grouping on the results page. (’001 Patent, Abstract, Claim 1).
  • Technical Importance: This solution provides a direct, text-based warning system integrated into the search results page, improving the user's ability to efficiently identify relevant content without navigating away from the page. (Compl. ¶189; ’001 Patent, col. 2:52-3:6).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1. (Compl. ¶339).
  • The essential elements of claim 1 are:
    • Receiving one or more search term elements from a user's device;
    • Generating at least one Internet search result referencing a webpage, displayed as a "search result grouping" containing a title, link, excerpt, or URL;
    • Determining to generate an annotation if at least one search term element is "missing" in the referenced webpage;
    • The annotation is "comprised of a text representing the at least one search term element that is missing"; and
    • Causing the annotation to be displayed "adjacent to or within" the search result grouping.
  • The complaint also discusses dependent claims 5 (related to descendant webpages) and 9 (related to a filtering function). (Compl. ¶192, ¶193).

U.S. Patent No. 11,100,184 - “Internet Search Results Annotation, Filtering, and Advertising With Respect to Search Term Elements”

  • Patent Identification: U.S. Patent No. 11,100,184, titled “Internet Search Results Annotation, Filtering, and Advertising With Respect to Search Term Elements,” issued August 24, 2021 (the “’184 Patent”). (Compl. ¶223).
  • Technology Synopsis: The patent describes a method for improving an internet search system by generating a plurality of search results that includes a first type that contains all submitted search terms and a second type that is missing at least one. (Compl. ¶229; ’184 Patent, Claim 1[b]). The interface displays the second type with an annotation showing the missing term, enabling the user to "readily discern" the deficiency without opening the webpage, thereby enabling "faster execution" of the search process. (Compl. ¶229; ’184 Patent, Claim 1[e1]).
  • Asserted Claims: Independent Claim 1. (Compl. ¶352).
  • Accused Features: Google LLC's search results page, which is alleged to display both results that contain all search terms and results that are missing terms, with the latter being displayed with an annotation like "Missing: [term]". (Compl. ¶353, ¶356-361).

U.S. Patent No. 11,971,937 - “Internet Search Results Annotation, Filtering, and Advertising with Respect to Search Term Elements”

  • Patent Identification: U.S. Patent No. 11,971,937, titled “Internet Search Results Annotation, Filtering, and Advertising with Respect to Search Term Elements,” issued April 30, 2024 (the “’937 Patent”). (Compl. ¶261).
  • Technology Synopsis: This patent claims a system for providing an enhanced search interface that combines annotation and filtering. (Compl. ¶267). The system generates a first search result with a "first warning" that a search term is missing and a second search result without such a warning. (Compl. ¶267; ’937 Patent, Claim 15[e], [g]). Crucially, the interface also provides a "filtering option" that, when selected, causes an updated interface to be generated that "does not display the first Internet search result." (Compl. ¶267; ’937 Patent, Claim 15[i], [j]).
  • Asserted Claims: Independent Claim 15. (Compl. ¶365).
  • Accused Features: The Google LLC search system is accused of providing an interface with a "warning" (e.g., "Missing: exercise") and a "filtering option" (e.g., the hyperlink "Show results with: exercise"), which, when clicked, generates an updated search results page that no longer displays the original, annotated result. (Compl. ¶371, ¶375, ¶376).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the "Google Search Engine Products and Services" and "Google Search Engine Functionality," which primarily encompass the internet search results pages generated at www.google.com. (Compl. ¶7, ¶8).

Functionality and Market Context

The complaint alleges that when a user performs a search on Google LLC, the system generates a results page. (Compl. ¶39). For search results that link to webpages that are found to be missing one of the user's search terms, Google LLC's system allegedly displays an annotation, such as "Missing: [term]". (Compl. ¶139). The complaint further alleges that adjacent to this "Missing" annotation, Google LLC provides a second, hyperlinked annotation such as "Show results with: [term]". (Compl. ¶140). The complaint alleges that clicking this second annotation functions as a filter, causing Google LLC to generate and display a new, revised search results page. (Compl. ¶141, ¶375). A screenshot in the complaint shows a search result for "football exercise manual" that is annotated with "Missing: exercise" and a clickable link "Show results with: exercise". (Compl. ¶138, p. 30). The complaint asserts that these features improve the functionality of Google LLC's search page and have been popular with users. (Compl. ¶122, ¶143).

IV. Analysis of Infringement Allegations

’959 Patent Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
[a] receiving a search request provided by the user from the computing device, the search request comprising one or more search term elements; Google LLC's servers receive a search request, such as "football exercise manual," from a user's device. ¶327 col. 5:21-25
[c] transmitting to the computing device, via an Internet, information comprising at least one automatically annotated Internet search result; Google LLC's servers transmit a search results page containing at least one result with an annotation (e.g., "Missing: exercise"). ¶329 col. 6:22-25
[e1] wherein the search result grouping comprises an annotation and at least one of: a title, an Internet link, an excerpt, or a URL; The accused search result includes a title, link, and excerpt, along with the "Missing: []" and "Show results with: []" annotations. ¶332 col. 6:35-39
[e2] wherein the annotation is provided in response to a presence or absence of the one or more search term elements in the referenced webpage; The "Missing: exercise" annotation is allegedly provided because the term "exercise" is absent from the referenced webpage. ¶333 col. 6:40-43
[e4] wherein the annotation comprises one or more search term elements missing in the referenced webpage and provides an indication that the automatically annotated Internet search result is less relevant with regard to what the user seeks. The annotation explicitly states the missing search term ("exercise") and allegedly indicates the result is less relevant to the user's query. ¶335 col. 6:47-52

’001 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
[a] receiving one or more search term elements supplied by a user of an Internet search engine from the user's computing device, Google LLC receives search terms (e.g., "exercise") from a user's device. ¶341 col. 12:4-7
[b1] wherein it is determined to generate the annotation if at least one search term element is missing in the Internet search result's referenced webpage, Google LLC's system allegedly determines to generate the annotation because the term "exercise" is missing from the target webpage. ¶346 col. 12:18-21
[b2] wherein the annotation is comprised of a text representing the at least one search term element that is missing in the Internet search result's referenced webpage; The annotation consists of the text "Missing: exercise," which represents the missing search term. ¶347 col. 12:22-25
[c] ...causing the annotation to be displayed adjacent to or within the Internet search result's search result grouping on the search results webpage. The "Missing: exercise" text is displayed within the grouping for the specific search result to which it pertains. ¶348 col. 12:26-30

Identified Points of Contention

  • Scope Questions: A central question may be the scope of "removed from being displayed" as recited in dependent claims of the ’959 and ’001 patents and independent claim 15 of the ’937 Patent. The complaint alleges that Google LLC's function of generating a new search results page meets this limitation. (Compl. ¶375, ¶376). The defense may argue that this language requires dynamic alteration of the existing webpage, rather than navigation to a new one.
  • Technical Questions: For claim 11 of the ’959 Patent, a point of contention may be what evidence is required to prove that the "Missing: [term]" annotation "provides an indication that the... result is less relevant." The complaint alleges this is inherent in the warning (Compl. ¶335), but whether this meets a potential technical or factual burden of proof raises an evidentiary question for the court.

V. Key Claim Terms for Construction

Term for Construction: "annotation"

  • Context and Importance: This term is foundational to all asserted patents. Its construction will determine the range of accused functionalities, as nearly every asserted claim requires an "annotation." Practitioners may focus on this term because the patents' specification describes various forms of annotations, from simple abbreviations to lists of terms, creating a potential dispute over whether the term is limited to specific disclosed embodiments.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function more broadly, stating a search result may be "symbolically annotated to convey... specific characteristics" of the webpage, suggesting any symbol or text conveying such information could qualify. (’959 Patent, col. 6:26-29).
    • Evidence for a Narrower Interpretation: The figures and detailed descriptions show specific implementations, such as abbreviations (e.g., "NP" for "Null Partial") or lists of the user's original search terms with visual treatments to indicate presence or absence. (’959 Patent, Fig. 3, Fig. 5). A party could argue these specific examples define and limit the scope of the term.

Term for Construction: "removed from being displayed on the search results webpage" (’959 Patent, Claim 16)

  • Context and Importance: This phrase is key to the filtering functionality claimed in multiple patents. The infringement theory for this element relies on Google LLC generating a new search page that omits a prior result. The complaint provides a visual comparison to illustrate this alleged removal. (Compl. ¶375, p. 119). The viability of this infringement theory may depend entirely on the construction of "removed."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that with filtering, "certain search results may be... deleted from the search results webpage such that the user never sees them." (’959 Patent, col. 6:29-33). This user-centric language could support an interpretation where causing the result to no longer be visible to the user, even by loading a new page, constitutes removal.
    • Evidence for a Narrower Interpretation: The phrase "removed from being displayed on the search results webpage" could be read to require an action that modifies the currently displayed page, rather than replacing it with a different page. The patent also discusses a dialog box for setting filtering criteria that alters what is "displayed or not displayed on a search results webpage," which may suggest modification of a single page's contents. (’959 Patent, col. 5:4-9).

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain separate counts for indirect infringement.
  • Willful Infringement: The complaint does not explicitly allege willful infringement or plead facts related to pre-suit knowledge of the patents. The prayer for relief includes a request for "enhanced damages," which is the statutory remedy for willful infringement. (Compl. p. 121, ¶e).

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

  • A central issue will be one of patent eligibility: do the claims, which focus on identifying and presenting information about missing search terms in a GUI, represent a concrete technological improvement to computer functionality, or are they directed to the abstract idea of categorizing and presenting information? The complaint's extensive pre-emptive arguments on this topic, including citations to Google LLC's own patent prosecution history, signal this as a primary anticipated battleground.
  • A key question of claim scope will be whether Google LLC's functionality of generating an entirely new search results page meets limitations requiring a search result to be "removed from being displayed on the search results webpage." The outcome of this construction could determine infringement of the filtering-related claims.
  • The case may also turn on a definitional question: does a simple textual statement that a search term is "Missing" inherently provide the claimed "indication that the... result is less relevant," or is that a distinct functional requirement that Plaintiff must separately prove is met by the accused system?