Linfo IP LLC v. Vedder Holsters LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Vedder Holsters, LLC (Florida)
  • Plaintiff’s Counsel: Law Office of Victoria E. Brieant, P.A.
• Case Identification: 5:25-cv-00160, M.D. Fla., 03/10/2025
• Venue Allegations: Venue is asserted based on Defendant having a regular and established place of business in the Middle District of Florida and conducting substantial business within the district.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for organizing and displaying electronic data objects based on a calculated "importance value."
• Technical Context: The technology addresses information overload by providing systems to sort and visually distinguish large sets of unstructured data (e.g., files, contacts, or items in a feed) based on relevance criteria beyond simple alphabetical or chronological order.
• Key Procedural History: The complaint states that the Plaintiff is a non-practicing entity and that it and its predecessors have entered into prior settlement licenses. It notes, however, that these licenses did not involve the production of a patented article and that the settling entities did not admit infringement, which may be relevant to future damages and marking arguments.

Case Timeline

Date	Event
2013-03-25	’131 Patent Priority Date
2016-08-30	’131 Patent Issued
2025-03-10	Complaint Filed

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 August 30, 2016

The Invention Explained

• Problem Addressed: The patent identifies the problem of "information overload," where users are presented with a large volume of data in formats like social network feeds, email inboxes, or search results, making it difficult to discern valuable information from irrelevant items (ʼ131 Patent, col. 1:20-36).
• The Patented Solution: The invention provides methods to organize unstructured "electronic objects" by assigning them "importance measures." These measures can be based on content analysis, metadata, or user-specified criteria. The system then displays the objects in a way that visually distinguishes their relevance, for example, by grouping them into separate, concurrently viewable areas or by applying different visual effects, such as a larger font size for more important items (’131 Patent, Abstract; col. 2:5-15; Fig. 3).
• Technical Importance: The described methods offer a more nuanced approach to data presentation than conventional sorting, aiming to improve user efficiency in information-intensive environments by personalizing the display based on calculated relevance (’131 Patent, col. 1:48-52).

Key Claims at a Glance

• The complaint asserts one or more of claims 1-20 (Compl. ¶9). The primary asserted independent method claim appears to be Claim 1.
• Independent Claim 1 requires:
  • obtaining a plurality of electronic objects, wherein the electronic objects comprise currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book;
  • displaying the electronic objects or their names or icons in a user interface;
  • receiving an importance value associated with at least one of the electronic objects, where the importance value is a numerical value entered by a user, transformed from user-specified text, or transformed from a user interface selection;
  • determining a position to place the electronic objects in the user interface directly from the importance value; and
  • placing the electronic objects in that determined position in the user interface.
• The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the website "https://www.vedderholsters.com" and its associated systems, methods, and user interface (Compl. ¶3, ¶9, ¶12).

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). It also refers to "review platforms" on the website (Compl. ¶12). The complaint does not, however, provide specific details on the operational features of the website, such as its product sorting, filtering, or display functionalities, that are alleged to practice the claimed methods.

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart in "Exhibit B" to support its infringement allegations but does not include this exhibit in the filing (Compl. ¶10). The narrative infringement theory suggests that the defendant's website, an e-commerce platform for firearm holsters, infringes the ’131 Patent. The core allegation is that the website's functionality for organizing and presenting information—presumably product listings or customer reviews—constitutes the patented method (Compl. ¶9). This theory would require showing that the website's system: (1) treats its product listings or reviews as "electronic objects"; (2) receives or calculates an "importance value" based on user interactions (such as sorting or filtering); and (3) uses that value to determine the position of those objects on the screen.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over whether product listings on a public e-commerce website qualify as "electronic objects" under the claim language, which explicitly lists examples like "files or file folders... contacts in a contact list or address book." The interpretation will question whether the patent's scope is confined to personal data management tools or extends to public-facing commercial websites.
  • Technical Questions: The complaint lacks specific factual allegations detailing which feature of the accused website performs the function of "receiving an importance value." A key technical question will be what evidence demonstrates that a standard e-commerce function, such as sorting by price or filtering by a product attribute, meets the "importance value" limitation as it is described and claimed in the patent.

V. Key Claim Terms for Construction

• "importance value"

  • Context and Importance: This term is the central mechanism of the asserted claims. Its construction will be critical in determining whether conventional e-commerce sorting and filtering functionalities fall within the scope of the patent. Practitioners may focus on this term because its interpretation dictates the breadth of the invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 defines the term as a value that can be transformed from a "selection of a user interface object indicated by a user" (’131 Patent, col. 23:32-35). This could be argued to encompass any user click on a sorting or filtering button.
    • Evidence for a Narrower Interpretation: The patent’s detailed description and figures repeatedly illustrate the "importance value" as a granular, non-binary numerical score (e.g., "0.95," "0.8") or a selection from a multi-level scale (e.g., "High normal low," a 1-5 scale) that a user explicitly assigns to a relevance criterion (’131 Patent, Fig. 2A, 2B, 2C). This could support a narrower construction requiring more than a simple binary filter selection.

• "electronic objects... compris[ing] currently existing files or file folders... contacts in a contact list"

  • Context and Importance: The applicability of the patent to the accused e-commerce website hinges on whether product listings are considered "electronic objects" as defined by this claim language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The use of the open-ended transition word "comprising" suggests the list of examples is not exhaustive. The specification also refers to an "information object in general," which could include "a message object in a feed or an email," potentially broadening the scope beyond personal files and contacts (’131 Patent, col. 3:41-43).
    • Evidence for a Narrower Interpretation: A court could find that the specific list of examples—files, folders, contacts—so strongly colors the meaning of "electronic objects" that the term should be limited to the context of personal information management systems, rather than public-facing e-commerce product catalogs.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant instructs its customers on how to use the infringing services (Compl. ¶11). It also pleads contributory infringement, alleging the accused service is not a staple commercial product and that Defendant knew its use would be infringing (Compl. ¶12). The factual support for these allegations is not detailed beyond a general reference to "product instruction manuals" (Compl. ¶12).
• Willful Infringement: Willfulness allegations are based on Defendant's alleged knowledge of the ’131 Patent "from at least the filing date of the lawsuit" (Compl. ¶11, ¶12). The complaint does not allege pre-suit knowledge but reserves the right to amend if discovery reveals an earlier date of knowledge.

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

• A core issue will be one of definitional scope: can the term "importance value," which is exemplified in the patent through granular, non-binary weighting systems, be construed to cover the conventional sorting and filtering functionalities common to most e-commerce websites?
• A key evidentiary question will be one of technical implementation: what specific evidence will Plaintiff present to demonstrate that the accused "vedderholsters.com" website actually performs the claimed method of receiving a user-defined "importance value" and using it to "determin[e] a position" for an object, as opposed to simply applying a standard database query that filters or sorts a list?