Querytron LLC v. Poshmark Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Querytron LLC (NM)
  • Defendant: Poshmark, Inc. (DE)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00956, D. Del., 07/30/2025
• Venue Allegations: Venue is asserted based on Defendant's alleged established place of business within the District of Delaware, as well as alleged acts of infringement and harm occurring in the district.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce platform infringes a patent related to enhancing internet search results by integrating seller-specific reputation information.
• Technical Context: The technology addresses methods for improving online search by displaying information about sellers, such as user-generated ratings, directly within a list of search results to help buyers evaluate potential sellers.
• Key Procedural History: The complaint asserts a single patent issued in January 2020 from an application filed in January 2006. The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history concerning the patent-in-suit.

Case Timeline

Date	Event
2004-01-05	Priority Date for U.S. Patent No. 10,534,820
2020-01-14	U.S. Patent No. 10,534,820 Issued
2025-07-30	Complaint Filed

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

U.S. Patent No. 10,534,820 - "Enhanced buyer-oriented search results"

The Invention Explained

• Problem Addressed: The patent asserts that conventional internet search results are "seller-oriented," as sellers can manipulate their ranking through various means, leaving a prospective buyer with little reliable information to assess a seller's quality or trustworthiness (ʼ820 Patent, col. 2:4-21). This forces buyers to sift through a "staggering" number of results without adequate data to make informed decisions (ʼ820 Patent, col. 1:60-64).
• The Patented Solution: The invention proposes a system to enhance search results with "buyer-oriented" information by associating "selling entities," defined as individual persons, with specific URLs (ʼ820 Patent, cl. 1, 11). The system collects ratings and other "seller-specific information" from buyers who have transacted with these sellers and presents this information directly in the search results page, next to the corresponding URL (ʼ820 Patent, Abstract; col. 4:26-47). This allows a user to evaluate sellers based on peer-generated data before clicking on a search result (ʼ820 Patent, col. 10:45-49).
• Technical Importance: The technology aims to integrate reputation and trust metrics, typically found within closed e-commerce ecosystems, into the broader context of internet search to provide more useful, unbiased information to buyers (ʼ820 Patent, col. 2:51-57).

Key Claims at a Glance

• The complaint alleges infringement of one or more claims, including exemplary claims identified in an exhibit not attached to the complaint itself (Compl. ¶11). Independent claim 11 is representative of the patent's core method.
• Independent Claim 11 includes the following essential elements:
  • A method for facilitating business-to-business personal connections by enhancing internet search engine results.
  • Generating and transmitting for display seller-specific information of one or more selling entities associated with a URL in a list of search results.
  • The selling entities are "individual persons."
  • The seller-specific information comprises "attributes" of the selling entities.
  • The seller-specific information "indicates a count of selling entities... who are currently involved in ongoing relationships that permit corresponding buying entities... to re-rate, in the future, the selling entities."
• The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products," which, based on Defendant's business, are understood to be the POSHMARK online e-commerce platform, including its website and mobile applications (Compl. ¶11).

Functionality and Market Context

The Poshmark platform allows users to search for products sold by a multitude of individual sellers (Compl. ¶3). The platform's search results functionality is alleged to practice the technology claimed by the ʼ820 Patent (Compl. ¶16). Publicly available information indicates that when users perform a search on the Poshmark platform, the results often include not only product listings but also seller-specific information, such as seller usernames, ratings, and other metrics intended to inform a buyer's purchasing decision.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2 (Compl. ¶16). As this exhibit was not provided with the complaint, a claim chart summary cannot be constructed. The infringement theory for a representative claim is summarized below in prose.

The complaint alleges that Poshmark's platform directly infringes the ʼ820 Patent (Compl. ¶11). An infringement theory based on claim 11 would likely allege that when a user conducts a search on the Poshmark platform, Poshmark's servers perform a method of: (1) generating a list of search results, where each result is associated with a URL; and (2) transmitting for display "seller-specific information" (e.g., seller ratings, number of sales, or other profile data) associated with the "selling entities" (the individual sellers on the platform). The central allegation would be that this displayed information meets the claim limitation of indicating a "count of... ongoing relationships."

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The patent repeatedly frames the invention in a "business-to-business" context (ʼ820 Patent, cl. 11; col. 8:48-51). A central question may be whether the ʼ820 Patent's claims, which describe a "business-to-business personal connections" method, can be construed to cover Poshmark's marketplace, which is predominantly consumer-to-consumer (C2C).
  • Technical Questions: Claim 11 requires the displayed information to indicate a "count of... ongoing relationships that permit... re-rat[ing]." The specification describes "ongoing relationships" as the final phase of a specific multi-stage "pipeline" (ʼ820 Patent, col. 11:5-16). A key technical question will be what evidence the complaint provides that Poshmark's system of displaying user ratings or transaction histories meets this specific, structured definition of an "ongoing relationship."

V. Key Claim Terms for Construction

• The Term: "ongoing relationships"

• Context and Importance: This term appears to be a critical limitation differentiating the claimed method from a simple display of transaction history or a one-time rating. The viability of the infringement claim may depend on whether Poshmark's seller metrics can be characterized as tracking these specific relationships. Practitioners may focus on this term because its definition appears to be highly specific within the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that the plain meaning of "ongoing relationship" is not limited to the specific embodiment, and that any system allowing for continued interaction or future rating between a buyer and seller would suffice.
  • Evidence for a Narrower Interpretation: The specification explicitly describes a multi-phase "pipeline" where the "ongoing relationship" phase is the final and potentially "never-ending" stage (ʼ820 Patent, col. 11:11-16). This detailed description could support a narrow construction that requires the accused system to implement a similar structured, multi-phase process.

• The Term: "selling entities [who] are individual persons"

• Context and Importance: This term defines the actors in the claimed method and is tied to the patent's goal of facilitating "personal connections" (ʼ820 Patent, cl. 11). The dispute will likely involve whether Poshmark's users, who are primarily consumers selling personal items, qualify as the "selling entities" contemplated by the patent's "business-to-business" framework.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language requires only that they be "individual persons," which could be argued to include any non-corporate seller, fitting the Poshmark model.
  • Evidence for a Narrower Interpretation: The patent consistently describes a "business-to-business connectivity service" (ʼ820 Patent, col. 9:20-21) and uses examples like a "salesman who works for a company" (ʼ820 Patent, col. 6:22-24). This context could support an interpretation requiring the "individual persons" to be acting in a professional or commercial capacity.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Poshmark 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).
• Willful Infringement: The complaint bases its allegation of knowledge on the service of the complaint itself, suggesting a claim for post-suit willful infringement (Compl. ¶¶13, 15). No facts are alleged to support pre-suit knowledge of the ʼ820 Patent.

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

• A core issue will be one of definitional scope: can the patent's "business-to-business" framework and its specific terminology be construed broadly enough to read on the consumer-to-consumer interactions that characterize the accused Poshmark platform?
• A key evidentiary question will be one of functional equivalence: does the seller information displayed by Poshmark (such as ratings and sales history) perform the specific, narrowly-defined function of indicating a "count of... ongoing relationships" as contemplated by the patent's detailed "pipeline" structure, or is there a fundamental mismatch in technical operation?
• A third question will concern claim construction: how the court defines "selling entities" and "ongoing relationships" will likely be dispositive, as a narrow construction tied to the specification's B2B examples could create a significant hurdle for the plaintiff's infringement case.