DCT
1:25-cv-00955
Querytron LLC v. Getty Images Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Querytron LLC (New Mexico)
- Defendant: Getty Images, Inc. (Delaware)
- Plaintiff’s Counsel: Garibian Law Offices, P.C.
- Case Identification: 1:25-cv-00955, D. Del., 07/30/2025
- Venue Allegations: Venue is asserted based on Defendant’s established place of business within the District of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s systems for providing search results for digital media infringe a patent related to enhancing internet search results with seller-specific information and ratings.
- Technical Context: The technology addresses the problem of search result manipulation by integrating user-generated reputation data (e.g., seller ratings) directly into a search results page to help users better assess the trustworthiness of the results.
- Key Procedural History: The patent-in-suit is subject to a terminal disclaimer. The complaint alleges willful infringement and inducement based on knowledge acquired upon service of the complaint itself.
Case Timeline
| Date | Event |
|---|---|
| 2004-01-05 | ’820 Patent Priority Date (based on related application) |
| 2006-01-27 | '820 Patent Application Filing Date |
| 2020-01-14 | '820 Patent Issue Date |
| 2025-07-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,534,820 - "Enhanced buyer-oriented search results" (issued January 14, 2020)
The Invention Explained
- Problem Addressed: The patent asserts that conventional internet search results are "seller-oriented," meaning their ordering can be manipulated by sellers through techniques like hidden metadata, and the results lack qualitative information to help a buyer assess the seller's trustworthiness (Compl. ¶9; ’820 Patent, col. 2:22-35).
- The Patented Solution: The invention proposes a system that associates URLs in search results with registered "selling entities" (e.g., individual service providers). When a user performs a search, the system retrieves and displays "seller-specific information," such as ratings from previous buyers, alongside the corresponding search result ('820 Patent, Abstract). This process, illustrated in the flowchart of Figure 1, is designed to provide a buyer-oriented layer of trust and reputation data on top of standard search results ('820 Patent, Fig. 1; col. 3:1-10).
- Technical Importance: The technology aimed to provide a mechanism for injecting unbiased, user-generated qualitative data into search result pages, thereby countering seller-side search optimization and providing users with more reliable information for making decisions ('820 Patent, col. 2:52-58).
Key Claims at a Glance
- The complaint does not specify which claims of the '820 Patent are asserted, instead referring to "Exemplary '820 Patent Claims" in a referenced exhibit (Compl. ¶11). Claim 1, the first independent claim, is analyzed here as a representative example.
- Independent Claim 1 requires:
- A method for enhancing internet search engine results.
- Generating and transmitting for display seller-specific information for "selling entities" that are "individual persons."
- The seller-specific information is associated with a URL in a list of search results.
- The generating and transmitting step is performed by a "toolbar application" on the user's computer.
- The "toolbar application" adds the seller-specific information to the search result.
- The complaint states that Defendant infringes "one or more claims" of the patent, reserving the right to assert additional claims (Compl. ¶11).
III. The Accused Instrumentality
Product Identification
The complaint does not identify specific accused products by name, referring instead to "Exemplary Defendant Products" (Compl. ¶11). As the Defendant is Getty Images, Inc., the accused instrumentalities are presumably the search and content delivery systems operating on its websites, such as gettyimages.com.
Functionality and Market Context
The complaint alleges that the accused products practice the technology claimed by the '820 Patent but provides no specific operational details (Compl. ¶11). Instead, it incorporates by reference claim charts from Exhibit 2, which was not included with the public filing of the complaint (Compl. ¶16-17). The functionality at issue would involve the systems used by Defendant to allow users to search for digital media and the manner in which those search results, along with associated information about the content creators, are displayed. The complaint does not provide sufficient detail for analysis of the products' commercial importance or market positioning.
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint’s infringement allegations are contained in claim charts in an external exhibit not provided with the filing (Compl. ¶17). The following analysis is based on the language of representative Claim 1 of the '820 Patent and the general nature of the accused systems.
'820 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| generating and transmitting for display... seller-specific information of one or more selling entities associated with... a Uniform Resource Locator (URL) of a search result in the list of search results; | Defendant’s systems allegedly generate and display information associated with the creators of digital media (the "selling entities") alongside the media items presented in search results. | ¶11, ¶16 | col. 24:62 - 25:6 |
| wherein the one or more selling entities are individual persons; | The individual photographers, illustrators, and videographers whose content is licensed through Defendant’s platform are alleged to be the "individual persons" functioning as "selling entities." | ¶11 | col. 25:7-8 |
| wherein the seller-specific information comprises attributes of the one or more selling entities; | Information displayed with search results, such as a creator’s name or other metadata, is alleged to constitute the claimed "attributes." | ¶11 | col. 25:9-11 |
| wherein the step of generating and transmitting for display the seller-specific information is performed by a toolbar application executed on a computer from which the person entered the one or more query terms; | The complaint does not explain how this limitation is met. Plaintiff must allege that a component of Defendant's system, or a related client-side software component, functions as the claimed "toolbar application." | ¶11, ¶16 | col. 25:12-18 |
| and wherein the toolbar application adds the seller-specific information to the search result in the list of search result. | The component alleged to be a "toolbar application" is accused of modifying the search results to insert the creator-specific information. | ¶11, ¶16 | col. 25:19-21 |
Identified Points of Contention
- Scope Questions: A primary issue will be whether Defendant's web-based search system, which likely generates results pages on a server, can be construed to include a "toolbar application executed on a computer" as required by Claim 1. This claim language suggests a client-side program that intercepts and modifies a webpage, which raises the question of a potential mismatch with a standard server-side web application architecture.
- Technical Questions: What evidence can Plaintiff provide that the accused system includes a distinct component that "adds" information to a search result list, as opposed to simply generating a single, integrated page on the server from the outset? The claim's structure implies a two-step process (generate results, then add information via toolbar) that may not map to how Defendant's technology operates.
V. Key Claim Terms for Construction
- The Term: "toolbar application"
- Context and Importance: This term appears central to an infringement analysis of Claim 1. If Defendant's system does not use a "toolbar application," and the term is construed narrowly, there may be no literal infringement of this claim. Practitioners may focus on this term because its construction could be dispositive of infringement for at least one of the patent's independent claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent suggests that the function of enhancing search results could be performed by the "Internet search engine itself" as an alternative to a toolbar, which could be used to argue that "toolbar application" should not be read as strictly limiting ('820 Patent, col. 10:63-65).
- Evidence for a Narrower Interpretation: Claim 1 explicitly recites a "toolbar application." The specification provides a detailed description of this embodiment, explaining that the toolbar "intercepts" a page, "parses and modifies the source code of the page before the Internet browser displays the page," and then "causes the Internet browser to display the modified page" ('820 Patent, col. 10:52-62). This detailed description of a client-side interception and modification process could support a narrower construction limited to that specific implementation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The allegation of knowledge is based on service of the complaint (Compl. ¶15).
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after gaining "actual knowledge" of the '820 Patent through the filing of this lawsuit (Compl. ¶13-14).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: can the term "toolbar application", which the patent specification details as a client-side program that intercepts and modifies web pages, be construed to cover the integrated, server-side functions of Defendant's web-based search platform?
A key evidentiary question will be factual: what is the specific technical architecture of the accused Getty Images system? The complaint lacks the detail needed to assess whether any component performs the distinct functions of a "toolbar application" that "adds" information to a pre-existing search result list, as required by the explicit language of Claim 1.