DCT
8:25-cv-02690
Leap Tools Inc v. Light Link Solutions
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Leap Tools Inc. (Canada)
- Defendant: Light Link Solutions (India)
- Plaintiff’s Counsel: Reising Ethington PC
- Case Identification: 8:25-cv-02690, M.D. Fla., 10/06/2025
- Venue Allegations: Venue is alleged to be proper because the Defendant is not a resident of the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s product visualization software systems infringe a patent related to integrating interactive product visualizations into e-commerce websites using a single-page application architecture.
- Technical Context: The technology operates in the e-commerce and augmented reality sector, enabling online shoppers to visualize how products like flooring, paint, or furniture will look in a real-world environment, such as a photo of their own room.
- Key Procedural History: The complaint alleges that Defendant was aware of Plaintiff's "Roomvo" visualization system, created comparative advertising that Plaintiff claims is false, and directly contacted Plaintiff's clients. The asserted patent is subject to a terminal disclaimer.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-30 | '311 Patent Priority Date |
| 2022-01-01 | Plaintiff's commercial activity alleged to begin ("at least 2022") |
| 2024-06-25 | '311 Patent Issue Date |
| 2025-10-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,020,311 - "Systems and Methods for Product Visualization Using a Single-Page Application" (Issued June 25, 2024)
The Invention Explained
- Problem Addressed: The patent's background section describes the technical challenges of integrating product visualization tools into existing e-commerce webpages. Relying on external applications can corrupt website usage data, create communication errors that degrade the user experience, and prevent website operators from tracking user interactions within the visualization tool (Compl. ¶18; ’311 Patent, col. 1:22-44).
- The Patented Solution: The invention discloses a method to embed a visualization tool directly into a webpage as a "single-page application," which avoids the need to reload the page or navigate to a new one. A client system (e.g., a user's browser) requests a script from a host system while rendering an e-commerce page. This script then modifies the webpage to include the visualization application, allowing a user to select a product and see it rendered in a chosen image, such as a photo of their own room (’311 Patent, Abstract; col. 3:51-59; Fig. 2).
- Technical Importance: This approach is designed to simplify the process for e-commerce operators to add sophisticated augmented reality features to their websites, creating a more seamless and interactive user experience that can increase consumer confidence in purchasing decisions (Compl. ¶9).
Key Claims at a Glance
- The complaint asserts independent method claim 11 (Compl. ¶21, ¶36).
- The essential elements of Claim 11 are:
- A client system provides a request for a script from a host system while rendering a webpage.
- The client system executes the received script, causing it to perform a series of operations, which include:
- modifying the webpage to include a visualization application when a user selects a visualization control;
- providing, from that application, a request to display a product in a first image; and
- receiving, by the application, instructions for displaying a second, modified image that depicts the product in the first image.
- The complaint alleges infringement of claims "including but not limited to claim 11" (Compl. ¶36).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant’s "Tilesview visualization system" and "Rugview visualization system" (collectively, "the Accused Products") (Compl. ¶23-24).
Functionality and Market Context
- The complaint describes the Accused Products as "AI-powered" software platforms offered for sale or use in the United States via websites such as tilesview.ai (Compl. ¶16, ¶27). The screenshot provided in the complaint shows the Tilesview system marketed as a tool for "multi-surface visualization," covering products like walls, flooring, rugs, and paint (Compl. p. 7). The systems are alleged to allow a user on a device like a laptop or mobile phone to render a webpage, select an item for visualization, and have the webpage be modified to display the selected item within a room scene (Compl. ¶29-30).
IV. Analysis of Infringement Allegations
'311 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for visualizing products in a single-page application, comprising: | Defendant's Tilesview and Rugview systems are visualization platforms for seeing products in a space. A screenshot of Defendant's website advertises "Future of Room Visualization" (Compl. p. 10). | ¶26-27 | Abstract |
| providing, by a client system, a request for a script associated with a host system during rendering of a webpage received from the host system; | A user's device renders a webpage from a host (e.g., Defendant's website), which initiates the visualization process. A screenshot from a video shows the visualization tool operating on a mobile device within a browser context (Compl. p. 10). | ¶29 | col. 8:46-56 |
| executing, by the client system, the script received in response to the request to cause the client system to perform operations comprising: modifying the webpage to include a visualization application in response to a selection of a visualization control in the webpage by a user of the client system; | The user selects an item on the webpage, which causes the page to be modified to display the item within the visualizer. | ¶30 | col. 10:63-66 |
| providing, from the visualization application, a request to display a product in a first image; | The user chooses a product to be visualized within a displayed image (e.g., a room scene). A screenshot from a promotional video shows a user selecting a "Green Floral" tile to place in the scene (Compl. p. 11). | ¶30 | col. 12:17-20 |
| and receiving, by the visualization application, instructions for displaying a second image depicting the product in the first image. | The user's device receives information that results in the display of a new image showing the selected product placed within the original room scene. A screenshot depicts the final rendered image with the selected flooring pattern applied (Compl. p. 12). | ¶30 | col. 16:36-38 |
Identified Points of Contention
- Scope Questions: A potential area of dispute may be the definition of a "single-page application." The infringement analysis may turn on whether the accused systems' method of modifying a webpage to display a visualization meets the specific technical requirements of an SPA as understood in the patent, or if it uses a different web architecture that falls outside the claim scope.
- Technical Questions: Claim 11 requires "receiving... instructions for displaying a second image." The complaint's evidence does not specify the technical nature of these instructions. A question for the court will be what the accused system actually receives from its server—a fully pre-rendered image file, or data such as a 3D model and parameters that the client system uses to render the image locally. The patent specification appears to contemplate both possibilities, which could become a central point of the technical infringement analysis (’311 Patent, col. 7:4-8).
V. Key Claim Terms for Construction
The Term: "single-page application"
- Context and Importance: This term appears in the preamble of the asserted claim and is foundational to the patent's description of the invention. The determination of whether the Accused Products meet this definition will be critical to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a functional definition, describing the benefit as allowing user interaction "without refreshing the webpage, opening a new webpage, or navigating away from the webpage" (’311 Patent, col. 1:55-59). This could support a construction that covers any technology achieving this functional outcome.
- Evidence for a Narrower Interpretation: The specification also describes the technical process of modifying the webpage's Document Object Model (DOM), which could support a narrower construction requiring this specific action (’311 Patent, col. 9:18-20).
The Term: "instructions for displaying a second image"
- Context and Importance: This final step of the claimed method defines the data received by the client to produce the visualization. Infringement will depend on whether the data transmitted by the Accused Products' servers constitutes these "instructions."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests this term can be broad, stating the instructions can include "the image, or a modified version of the image" or, alternatively, "a model of the product (e.g., a three-dimensional model, or the like)" that the client system can then render (’311 Patent, col. 7:4-8).
- Evidence for a Narrower Interpretation: Language describing user interactions like rotating a displayed product may suggest that the "instructions" must be more than just a static, pre-rendered image file, potentially requiring a model and rendering parameters that allow for dynamic manipulation on the client side (’311 Patent, col. 16:15-22).
VI. Other Allegations
Indirect Infringement
- The complaint alleges both induced and contributory infringement. The inducement claim is based on allegations that Defendant encourages its own customers (such as the company Exocera, whose website is shown to be "Powered By Tilesview") to implement the infringing visualization systems (Compl. ¶41-42; p. 13). The contributory infringement claim alleges Defendant provides a material apparatus (its software) that is especially adapted for infringement and not suitable for substantial noninfringing use (Compl. ¶46).
Willful Infringement
- The complaint alleges willful infringement based on Defendant's knowledge of Plaintiff's "Roomvo" product "and that it was patented" (Compl. ¶39). As evidence of knowledge, the complaint provides a screenshot of what it claims is Defendant's comparative advertising, which directly contrasts the features of "TilesView" and "Roomvo" (Compl. ¶33; p. 9).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of architectural scope: does the accused "Tilesview" system, which modifies a retailer's webpage to show products, operate as a "single-page application" as defined by the patent, or does its underlying technical implementation differ in a way that places it outside the claim's boundaries?
- A key evidentiary question will relate to the flow of information: what specific "instructions" does the accused system receive from its server to generate the final visualization? The case may turn on whether these instructions constitute the specific type of data contemplated by the patent for "displaying a second image," a technical detail not fully elucidated by the complaint's screenshots.
- Beyond direct infringement, a significant focus will likely be on the Defendant's state of mind: does the evidence of comparative advertising that names Plaintiff's product and direct outreach to Plaintiff's clients demonstrate knowledge and intent sufficient to support claims of indirect and willful infringement?