Linfo IP LLC v. Fanatics Holdings Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Fanatics Holdings, Inc. (Delaware)
  • Plaintiff’s Counsel: Law Office of Victoria E. Brieant, P.A.
• Case Identification: 3:25-cv-01124, M.D. Fla., 09/19/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a "regular and established place of business" in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and related systems infringe a patent related to methods for organizing and displaying unstructured data objects based on user-defined relevance.
• Technical Context: The technology addresses the problem of information overload by allowing users to assign importance scores to digital objects (e.g., files, contacts, messages) to filter and display them in a more useful manner than traditional chronological or alphabetical sorting.
• Key Procedural History: The complaint notes that Plaintiff is a non-practicing entity and has entered into prior settlement licenses with other entities. Plaintiff raises these facts to preemptively address potential defenses related to patent marking requirements under 35 U.S.C. § 287, arguing that no licensee was producing a patented article that would trigger a marking duty.

Case Timeline

Date	Event
2013-03-25	’131 Patent - Earliest Priority Date
2016-08-30	’131 Patent - Issue Date
2025-09-19	Complaint Filing Date

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

U.S. Patent No. 9,430,131 - "System, Methods, And User Interface For Organizing Unstructured Data Objects" (Issued Aug. 30, 2016)

The Invention Explained

• Problem Addressed: The patent's background section describes the problem of "information overload" where users are confronted with large amounts of data from sources like social network feeds, emails, and search engine results, making it difficult to find relevant information efficiently (’131 Patent, col. 1:20-47). Conventional methods for filtering or sorting are described as having limited functionality (’131 Patent, col. 1:43-47).
• The Patented Solution: The invention provides a system and user interface that allows a user to assign a granular "importance measure" or "relevance score" to unstructured electronic objects, such as files, folders, or contacts (’131 Patent, Abstract). Instead of a simple binary "important/not important" flag, the system uses non-binary values to rank objects. The system then displays these objects in different formats or in separate, concurrently viewable areas based on their assigned importance, with the goal of distinguishing more relevant objects from less relevant ones (’131 Patent, col. 2:7-16; FIG. 1).
• Technical Importance: The technology aims to provide a more effective way to manage and navigate large collections of personal data by organizing it based on user-specified degrees of relevance, rather than relying solely on system-level metadata like creation date or file name (’131 Patent, col. 1:48-56).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). Independent claims are 1, 9, and 18.
• Independent Claim 1 (Method):
  • Obtaining a plurality of electronic objects, comprising currently existing files, file folders, directories, contacts in a contact list, or address book;
  • Displaying the electronic objects or their names/icons in a user interface;
  • Receiving a non-binary numerical importance value associated with at least one object, where the value is entered by a user;
  • Determining a position to place the object in the user interface directly from the importance value; and
  • Placing the object or its name/icon in that position in the user interface.
• The complaint does not explicitly reserve the right to assert dependent claims, but the assertion of claims 1-20 implicitly includes them.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the website https://www.fanatics.com and its related systems and services (collectively, "Products") (Compl. ¶3).

Functionality and Market Context

The complaint alleges that Defendant "maintains, operates, and administers a system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). The complaint does not provide further specific details on which features of the Fanatics e-commerce platform are accused of infringement, such as its product search and filtering tools, user review displays, or other content presentation systems. The complaint broadly accuses the Products of being used for "conducting electronic commerce" (Compl. ¶8).

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations but does not include the exhibit (Compl. ¶10). In the absence of a claim chart, the infringement theory must be drawn from the complaint’s narrative allegations. The core allegation is that the Defendant's Products constitute a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" that infringes the ’131 Patent (Compl. ¶9). The complaint does not provide sufficient detail to map specific functionalities of the Fanatics website to the elements of the asserted claims.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A primary issue may be whether the product listings, search results, or other content on the Fanatics e-commerce website qualify as "electronic objects" under the definition in Claim 1, which explicitly lists "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 18:4-7). The interpretation of this term may be central to determining if the patent's scope covers the accused instrumentality.
• Technical Questions: The complaint does not identify a feature on the Fanatics website that allows a user to input a "non-binary numerical importance value" to re-order content, a central requirement of independent claim 1. A key factual question will be whether any feature of the accused system, such as a "sort by relevance" option, can be characterized as receiving a user-entered importance value, as opposed to being a purely algorithmic function.

V. Key Claim Terms for Construction

• The Term: "importance value" (Claim 1)

• Context and Importance: This term is the core of the invention. Its construction will determine what user actions satisfy the infringement criteria. The dispute will likely center on whether a user's single click on a pre-defined sort option (e.g., "Sort by Relevance") constitutes "receiving an importance value... entered by a user," or if the term requires a more explicit, granular input, like assigning a numerical score.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states the value can be "transformed from a text specified by a user" or "transformed from a selection of a user interface object indicated by a user," which could suggest that actions other than direct numerical entry are contemplated (’131 Patent, col. 18:21-25).
  • Evidence for a Narrower Interpretation: Claim 1 requires a "non-binary numerical value," and the specification’s examples depict interfaces where users assign specific numbers (e.g., values on a 1-5 scale or a 0-1 scale) to criteria, suggesting an explicit, quantitative user input (’131 Patent, FIG. 2A, 2C, 6A, 6B).

• The Term: "electronic objects" (Claim 1)

• Context and Importance: The applicability of the patent to the accused e-commerce platform depends heavily on whether product listings or search results are considered "electronic objects" as defined by the claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that, at a technical level, product listings stored in a database on a server are a form of "files" or data objects within a "computer file system," and that the claim language should not be limited to a layperson's view of a desktop file explorer.
  • Evidence for a Narrower Interpretation: The claim language is highly specific: "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 18:4-7). This list appears to describe objects within a personal computing or file management context, not dynamically generated content on a commercial website. A party may argue the plain meaning of these terms excludes database entries presented as product listings.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it asserts Defendant "actively encouraged or instructed others" on how to use the infringing services (Compl. ¶11). For contributory infringement, it alleges the accused products are not staple articles of commerce and are offered with instructions for an infringing use (Compl. ¶12). These allegations are made without reference to specific evidence, such as user manuals or advertisements.
• Willful Infringement: Willfulness allegations are based on knowledge of the ’131 Patent "from at least the filing date of the lawsuit" (Compl. ¶¶11-12). The complaint does not allege any facts that would support a finding of pre-suit willfulness.

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

1. Definitional Scope: A core issue will be whether the asserted claims, which appear directed to organizing personal data like files and contacts, can be construed to cover the presentation of commercial product listings on an e-commerce platform. The resolution will depend on the construction of the term "electronic objects."
2. Factual Infringement: A central evidentiary question will be whether the Fanatics website includes any functionality that meets the claim requirement of receiving a "non-binary numerical importance value" that is "entered by a user" to re-order content. The complaint provides no specific facts identifying such a feature.
3. Pleading Sufficiency: Given the complaint’s lack of specific factual allegations mapping accused features to claim limitations, an initial question for the court may be whether the complaint meets the plausibility standard for patent infringement pleading required under federal law.